With no formal end to the COVID-19 public health emergency in sight, CMS announced new flexibilities for clinicians participating in the Merit-Based Incentive Program (MIPs) for 2020.  Clinicians who have been significantly impacted by the COVID-19 pandemic may apply to have any or all of their MIPs performance categories reweighted under the program’s extreme and uncontrollable circumstances policies.

CMS provided a similar flexibility during the 2019 MIPs submission window, which prevented clinicians from receiving a negative payment adjustment during the 2021 payout year.  This flexibility was applied automatically to clinicians who did not report data on required performance categories. CMS is still in the process of finalizing scores from the 2019 performance period.

The 2020 extreme and uncontrollable circumstances application is open through December 31, 2020, allowing clinicians, groups and virtual groups to request reweighting of one or more MIPS performance categories to 0%. Applications are reviewed on a case-by-case basis, and if approved, the performance categories included in the application are weighted at 0% and will not contribute to your final score unless you submit MIPS data for the 2020 performance period. Submitting data will void approved applications.  For example, a group is approved to have the Quality category reweighted but submits quality data anyways, they will receive a score for the Quality category.  If all categories are reweighted to 0%, the MIPs participant will receive a neutral payment adjustment in the 2022 payout year.

Applications may be completed through the Quality Payment Program (QPP) portal account or by a third-party service, such as a qualified registry or QCDR.  Supporting documentation is not required when applying. However, clinicians, groups and virtual groups should retain documentation of their circumstances supporting their application for their own records in the event they are selected by CMS for data validation or audit.

Similar flexibilities for Alternative Payment Model (APM) Entities are being explored and CMS states that more information will be available soon.

CMS released additional fact sheets with their announcement available below:

2020 Exception Application Fact Sheet

Quality Payment Program COVID-19 Response

As always, ADVOCATE will continue to keep you informed on the issues impacting medical groups as they develop.

Kayley Jaquet
Manager, Regulatory Affairs