(Editor’s Note: CMS announced on Dec. 2 that the deadline to file applications for the “extreme and uncontrollable circumstances” hardship exception for the 2020 performance year has been extended to Feb. 1, 2021.)
November 23, 2020, 2:39 pm News Staff -- Eligible clinicians in CMS’ Quality Payment Program who met eligibility thresholds for the Advanced Alternative Payment Model bonus in 2018, take note: The agency has granted qualifying participants extra time to ensure the accuracy of the billing information CMS has on file for them.
CMS announced in a Nov. 19 email that QPs eligible to receive a 5% Advanced APM bonus for the 2018 performance year whose names are included on a list the agency has compiled now have until Dec. 13 ― a one-month extension ― to update their billing information. That list appears as an Excel spreadsheet in a zip file clinicians can download from the QPP website. The file also contains instructions for updating that billing information and forms required to do so.
According to the QPP, eligible clinicians who meet the applicable payment amount or patient count thresholds in an Advanced APM for a given performance year are deemed QPs for that year and eligible for a 5% bonus payment. Any such payment, which is based on the paid amounts for Medicare Part B-covered professional services, will be made two years after the performance period.
CMS began notifying 2018 QPs in September of their eligibility to receive the 5% APM bonus this year. At the same time, the agency sent letters to QPs for whom current Medicare billing information could not be verified, in addition to publishing their names.
Eligible QPs who have not been notified about difficulties with their APM bonus payment may log in to the QPP portal to review payment details.
QPP participants should also be aware of other looming deadlines and important dates. Two, in particular, stand out.
Dec. 31 marks the cutoff to apply for an “extreme and uncontrollable circumstances” hardship exception or a “promoting interoperability” hardship exception for the Merit-based Incentive Payment System 2020 performance year.
The extreme and uncontrollable circumstances exception is intended to provide relief for practices that have experienced difficulty in collecting and reporting MIPS performance data because of circumstances beyond their control; the COVID-19 Public Health Emergency is an obvious example of such circumstances. Specifically, CMS announced that it will allow individual clinicians, groups and virtual groups to request reweighting of one or more MIPS performance categories in 2020.
The agency this spring automatically granted practices this exception for reporting 2019 performance data, but practices must apply to receive it for 2020. Practices that do not secure the exception have until March 31 to report their data.
In addition, CMS noted that it had previously introduced a high-weighted COVID-19 clinical trials improvement activity that offers clinicians an opportunity to receive MIPS credit for the important research work they are already doing.
Individual clinicians, groups and virtual groups that faced certain issues with their certified EHR can apply for the promoting interoperability hardship exception, citing one of the following reasons:
Note that simply lacking CEHRT does not qualify a practice to reweight its interoperability performance category to 0%.
Dec. 31 is also the deadline for individual clinicians and groups to form virtual groups for the 2021 performance year. Download the 2021 Virtual Group Toolkit zip file to find out more about the process. The toolkit contains the 2021 MIPS Virtual Group Election Process Guide and the 2021 MIPS Virtual Group Participation Fact Sheet. The guide lists important dates and gives and overview of the virtual group two-step election process. The fact sheet provides detailed information about participating in MIPS as a virtual group.
Lastly, keep in mind some key dates in 2021: