MIPS eligible providers who qualify for the facility-based special status will not be able to rely on that reporting option for the 2021 performance year.
Beginning in 2019, clinicians who furnished 75 percent or more of their covered professional services in a hospital setting, including at least one inpatient or emergency room service, and who also were assigned to a facility that received a Hospital Value-Based Purchasing (VBP) Program score, could receive quality and cost MIPS scores based on their assigned facility’s VBP score.
COVID-19 PHE Changes
However, in response to the ongoing COVID-19 public health emergency, CMS recently finalized policies for the 2022 Hospital VBP Program, including the suppression of measure data affected by the circumstances caused by the COVID-19 PHE. As a result, CMS also decided not to calculate a total performance score for any hospital for 2022 because “calculating a total performance score in the Hospital VBP Program for hospitals using only data from the remaining measures, all of which are in the Clinical Outcomes Domain, wouldn’t result in a fair national comparison.”
What Facility-Based Clinicians and Practices Should Do
Since the 2022 VBP Program total performance score would be used to calculate facility-based scores for 2021, CMS will not be calculating MIPS facility-based scores for the 2021 MIPS performance year. Instead, those facility-based clinicians and groups will need to submit data for MIPS quality measures via another reporting mechanism to receive a score other than zero for the quality performance category.
CMS will automatically calculate a score for the cost performance category for facility-based clinicians and groups that meet the case minimum for at least one MIPS cost measure. If case minimums are not met for any cost measures, the cost performance category will be reweighted to 0 percent and the weight redistributed to other performance categories. Either way, no other data needs to be collected or submitted for the cost performance category.
Facility-based clinicians and groups without available and applicable measures can request performance category reweighting by submitting an extreme and uncontrollable circumstances (EUC) application, citing “COVID-19” as the triggering event.
Other Reporting Requirements
As always, facility-based measurement would have applied only to the quality and cost performance categories. To maximize their final score, facility-based individuals, virtual groups, and groups will need to collect and submit data for the Improvement Activities and Promoting Interoperability performance categories.
However, MIPS scoring rules for special statuses and approved exceptions also apply to facility-based clinicians. For instance, hospital-based eligible clinicians, who furnish 75 percent or more of their covered professional services in a hospital setting, are not accountable for the promoting interoperability category. In their case, the PI category is reweighted to 0 and the 25 percent is reallocated to another performance category (or categories) when calculating the final score.
For more information, review the following resources:
- Reporting Factors Overview page of the Quality Payment Program Website
- Special Statuses page of the Quality Payment Program Website
- “How to Participate in MIPS 2020 with Facility-Based Measurement” from the CIPROMS blog
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