As part of the administration’s response to the COVID-19 pandemic, the Centers for Medicare & Medicaid Services (CMS) announced unprecedented exceptions and extensions to the Quality Payment Program (QPP) to free up the American healthcare system to focus time and resources towards patient care.

For providers participating in the Merit-Based Incentive Program (MIPs) and Medicare Shared Savings Program (MSSP) under the QPP, CMS has extended the submission window for 2019 performance year reporting by an additional 30 days. Eligible providers that fail to submit data by the new deadline of April 30th will automatically qualify for an extreme and uncontrollable circumstances hardship exception, granting a neutral payment adjustment in the 2021 payout year.  This would require that no data is submitted for any of the four performance categories. Full or partial submissions made during the 2019 submission window will be subject to regular scoring under the program.

CMS has made additional accommodations for hospital value-based purchasing and post-acute care programs, waiving data submission requirements for 2019 Q4 and 2020 Q1 and Q2 time periods.  For more detail, please see the announcement from CMS here.

Acknowledging that quality measure data collection and reporting during the health emergency may not be reflective of true levels of performance, CMS is further evaluating options to provide relief around participation for 2020 MIPs and MSSP.

As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.


Kayley Jaquet

Manager of Regulatory Affairs