March 15, 2021, 3:59 p.m. News Staff ― CMS announced last month that in response to the ongoing COVID-19 public health emergency, it is offering physicians participating in the Quality Payment Program’s Merit-based Incentive Payment System a data reporting reprieve for 2020 performance data, as well as other flexibilities.
Specifically, the agency said it will apply the MIPS automatic extreme and uncontrollable circumstances policy to all individual MIPS-eligible clinicians for the 2020 performance year. MIPS-eligible clinicians reporting as individuals will be scored only on performance categories for which they submitted data, with all other categories reweighted to 0% of their final score.
It’s a move the AAFP has strongly advocated, stating in a Jan. 29 letter to CMS Acting Administrator Elizabeth Richter that although COVID-19 vaccination efforts have begun, much of the country remains at risk, and physicians will need to stay focused on providing care “for the foreseeable future.”
The letter, signed by AAFP Board Chair Gary LeRoy, M.D., of Dayton, Ohio, went on to note that without CMS intervention, practices that are unable to apply for the EUC exception or that fail to submit data will face a negative 9% payment adjustment, further exacerbating the fragile financial situation many already are facing.
“By automatically applying the extreme and uncontrollable circumstances policy, CMS will relieve physicians of the burden of reporting and the stress associated with potential negative payment adjustments,” the letter observed.
The current letter largely echoes sentiments the Academy expressed one year ago regarding 2019 performance year data.
Here’s how other parts of CMS’ Feb. 25 announcement break down:
Because certain MIPS participants will need to apply for the exception, CMS is extending the deadline to complete EUC applications for the 2020 performance year from Feb. 1 to March 31 at 8 p.m. EDT.
The extended EUC application submission period will enable groups, virtual groups and alternative payment model entities to submit applications asking for performance category reweighting due to the COVID-19 PHE.
The agency emphasized that any MIPS participant that plans to complete and submit an EUC application must have a Health Care Quality Information Systems Access Roles and Profile account. More information on HARP accounts is available in the QPP Access User Guide.
It’s important to note that although CMS is extending the deadline to submit COVID-19-related EUC applications, 2020 data already submitted for individuals, groups or virtual groups cannot be overridden and will be scored.
MIPS-eligible clinicians who participate in virtual groups will need to submit an EUC application for all four performance categories (quality, cost, promoting interoperability and improvement activities) by the deadline.
Groups and virtual groups that have submitted data for a single performance category may apply to have all four categories reweighted. Unless these groups apply for and receive an EUC exception, they will be scored in all performance categories unless they are eligible for reweighting in one or more categories.
Groups and virtual groups that have submitted data for two or more performance categories will receive a MIPS payment adjustment based on their performance. Again, an EUC application will not override previously submitted data in such cases.
Participants in an alternative payment model may also submit an EUC application. APM entities must request reweighting for all four categories, however, and at least 75% of the entity’s eligible clinicians must be eligible for reweighting of the promoting interoperability category. Notably, APM entities may apply for the EUC exception even if they previously submitted data.
Additional information, along with answers to frequently asked questions, is available from CMS’ QPP COVID-19 Response Fact Sheet.