Among the many unknowns of the COVID-19 pandemic is what practices should do for the Quality Payment Program (QPP). Last week, practices finally got some answers when the Centers for Medicare & Medicaid Services (CMS) announced its plan for the 2020 QPP performance year, which will affect Medicare Part-B payments in 2022.
Practices participating in the Merit-based Incentive Payment System (MIPS) that have been significantly impacted by the public health emergency (PHE) — e.g., it has prevented a practice from collecting data for an extended period of time or it could affect the practice's performance on cost measures — can apply for the Extreme and Uncontrollable Circumstances Exception. This application allows practices to request that CMS reweight any or all MIPS performance categories to zero. If an individual category is reweighted, its weight will be shifted to the remaining categories. It is important to note that submitting data will override the reweighting of a category. For example, if you are approved to have the quality category reweighted to zero but still submit data, CMS will calculate a score for the quality category. Practices must submit data for at least two categories to receive a final score greater than the performance threshold, leading to a positive adjustment of their Medicare Part-B payments. If a practice requests to reweight more than two performance categories, it will receive a neutral payment adjustment in the 2022 payment year.
You may remember that CMS automatically applied the Extreme and Uncontrollable Circumstances Exception for the 2019 performance year. CMS automatically applies the policy if a practice is in an area where CMS has determined a qualifying event has occurred. CMS has not identified a qualifying event for the 2020 performance year. Therefore, practices must submit an Extreme and Uncontrollable Circumstances Application for the 2020 performance year.
Practices can contact the QPP Help Desk (866-288-8292) or review the following CMS resources for additional information:
— Erin Solis, Manager, Practice and Payment for the American Academy of Family Physicians
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