In response to the COVID-19 pandemic, the Centers for Medicare and Medicaid Services (CMS) announced it will exempt MIPS-eligible clinicians (EC) from up to a 9% negative payment adjustment for the 2020 reporting year (2022 payment year).
The Extreme and Uncontrollable Circumstances Hardship Exception (EUC) policy will be automatically applied to all MIPS ECs who did not submit MIPS data during the 2020 performance period. CMS also reopened the hardship exception application process for group practices, virtual groups and alternative payment model entities who missed the previous 2020 deadline and who submitted data in one MIPS category. Applications will be accepted through March 31.
However, groups and eligible clinicians that submit data in at least two MIPS categories will not receive an exception and will instead receive a MIPS score and the associated bonus or penalty.
MIPS payment adjustments are budget neutral, meaning negative payment adjustments pay for the positive payment adjustments. Without negative payment adjustments, ECs cannot earn positive payment adjustments unless they exceed the exceptional performance threshold, which is not subject to the budget neutrality requirement.
If you or your practice plan to participate in MIPS in 2020 in an effort to receive an exceptional performance bonus, the Advocacy Council suggests you consider submitting an application to reweight the Cost category to zero. The Advocacy Council has long had concerns about Cost category scoring and attribution for allergy/immunology, and COVID-19 could well skew Cost category results further. Postponement of preventive and routine care could skew patient attribution toward sicker patients, and inadequate risk adjustment could negatively affect patients facing economic hardships.
The EUC applies differently depending on if the EC reports as an individual, group or virtual group. It also applies differently depending on if the EC already reported some data or if they did not report any data.
For details on the new EUC policy, read the CMS QPP COVID-19 Response Fact Sheet. You can find additional information by downloading the 2020 MIPS Extreme and Uncontrollable Circumstances Application Resources.
The College has been advocating with CMS to lessen the burden of MIPS on practicing allergists. We are pleased CMS has taken these steps to ensure physicians will not be unduly penalized during the public health emergency. The Advocacy Council – we have you covered.