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Medicare Providers May Not Have to Submit MIPS Data in 2020 … But They Must Apply for the Exception!

July 01, 2020

Medicare Providers May Not Have to Submit MIPS Data in 2020 … But They Must Apply for the Exception!

If the COVID-19 pandemic prevents a MIPS eligible clinician from collecting 2020 MIPS performance period data (part of the Quality Payment Program (QPP)), or if the pandemic could impact your performance score on cost measures, providers may submit an exception application to have all, some or one of their MIPS performance scores reweighted to 0%.

In May, we reported that CMS opened the 2020 Promoting Interoperability and Extreme and Uncontrollable Circumstances Exception Application window for the 2020 Performance Year. CMS has now released the 2020 QPP Exception Applications Fact Sheet. Here are a few highlights:

Extreme and Uncontrollable Circumstances Exception

  • For Performance Year 2020, as of now, there are no qualifying events that have been identified for an automatic Extreme and Uncontrollable Exception. This means that if an eligible clinician wants an exception they must apply.

Although the deadline for the Extreme and Uncontrollable Circumstances Exception application is not until the end of the year, there is little guidance from CMS on how liberally they will grant these exceptions. To that end, we recommend that if you are considering applying for the Extreme and Uncontrollable Circumstances Exception, you should apply now. If the exception is not granted, then an eligible clinician may be penalized up to 9% on 2023 Medicare services!

  • The Extreme and Uncontrollable Circumstances Exception application allows you to request reweighting for any or all performance categories if you encounter an extreme and uncontrollable circumstance or public health emergency.

Promoting Interoperability Performance Category Hardship Exception 

  • The Promoting Interoperability Exception is automatic for certain provider types: ambulatory surgical center-based MIPS eligible clinicians, hospital-based MIPS eligible clinicians, non-patient facing clinicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, registered dietitian or nutrition professionals psychologists, registered dietitian or nutrition professionals
  • Providers may qualify for reweighting or the Promoting Interoperability exception based on one of the following reasons:
    • Insufficient internet connectivity 
    • Extreme and uncontrollable circumstances, including:
      • Disaster
      • Practice closure
      • Severe financial distress (bankruptcy or debt restructuring)
      • Vendor issues
    • No control over whether CEHRT is available 
    • Using decertified EHR technology 
    • Small practice
  • The Promoting Interoperability exception will result in reweighting the Promoting Interoperability performance category only! The 25 points from the Promoting Interoperability category will be added to the value of Quality in the overall Composite Score Calculation. 

Before the exception, the Composite Score Calculation may be:

If the exception is granted, the Composite Score Calculation may be:

The deadline to submit an application for both hardship exceptions is December 31, 2020. Eligible clinicians should submit the application through the QPP portal using a HARP account. If an eligible clinician is granted one of the exceptions, but then submits data, the data submission will override the reweighting on a category by category basis. 

Participation in the Quality Payment Program may help you mitigate your malpractice risk through tracking and improving quality care (Quality measures), increasing patient engagement and satisfaction (Improvement Activities) and improving communications using secure electronic transmissions between providers and with patients (Promoting Interoperability). 

For more information, contact LAMMICO Practice Management Specialist, Natalie Cohen, MBA, MHA, at 504.841.2727 or ncohen@lammico.com

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