The 2017 U.S. hurricane season, coupled with a horrendous spate of California wildfires, has created havoc for hundreds of thousands of people, including many family physicians with practices in affected areas.
"All of these disasters happened during the 2017 MIPS (Merit-based Incentive Payment System) transition year, so you might be wondering what they mean for your MIPS participation," notes CMS in a recent fact sheet(www.cms.gov) posted in its Quality Payment Program resource library.
The fact sheet details the extreme and uncontrollable circumstances policy for MIPS participation in 2017 that CMS outlined in an interim final rule(www.federalregister.gov) with comment period that was published in the Nov. 16 Federal Register.
In short, family physicians affected by these disasters have one less thing to worry about in coming months when it comes to MIPS reporting.
"We understand that if you live or practice where these disasters took place, you may not be able to collect or submit program data for a long time," says CMS.
Therefore, the agency notes, "Under this policy, if you're affected by Hurricanes Harvey, Irma or Maria or the Northern California wildfires, we've tried to lessen your burden by not requiring you to submit an application to reweight the performance categories. We'll be able to automatically identify you," and affected MIPS-eligible clinicians will "automatically receive a neutral MIPS payment adjustment."
The only exception would be for MIPS-eligible clinicians who have submitted data for any of the MIPS performance categories by the 2017 submission deadline, the fact sheet continues. Clinicians who have done so will be scored on each performance category for which they have submitted data according to existing MIPS scoring policies.
The three above-named hurricanes that occurred in August and September 2017 each qualify as a "triggering event" for the automatic policy covering extreme and uncontrollable circumstances, says CMS.
Specifically, the policy includes all
- 67 counties in Florida,
- 159 counties in Georgia,
- 64 parishes of Louisiana,
- 78 municipalities in Puerto Rico, and
- 46 counties of South Carolina, as well as the Catawba Indian Nation.
The automatic policy also covers all of the U.S. Virgin Islands and these 30 Texas counties: Aransas, Austin, Bee, Brazoria, Calhoun, Chambers, Colorado, Dewitt, Fayette, Fort Bend, Galveston, Goliad, Gonzales, Harris, Jackson, Jefferson, Jim Wells, Karnes, Kleberg, Lavaca, Liberty, Live Oak, Matagorda, Nueces, Refugio, San Patricio, Victoria, Waller, Wharton, and Wilson.
In addition, physicians affected by the California wildfires will also be granted exceptions without having to submit an extraordinary circumstances exception request if they are located in one of the California counties designated by the Federal Emergency Management Agency(www.fema.gov) as a major disaster county.
Counties included in that list are Butte, Lake, Mendocino, Napa, Nevada, Orange, Sonoma and Yuba. Physicians also have access to a CMS web page devoted to need-to-know information related to the aftermath of the 2017 California wildfires.(www.cms.gov)
Wondering why your county isn't included? According to language in the interim rule, the list of disaster areas will continue to be updated.
Need answers to immediate questions? Call CMS at 1-866-288-8292 Monday through Friday from 8 a.m. to 8 p.m. EST or email questions directly to the agency.
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