Do you qualify for 2020 MIPS exception?

Despite a global public health crisis, healthcare providers still need to think about Merit-Based incentive Payment System (MIPS) reporting. We know it’s been a tough time, and some providers may experience strong difficulties while collecting the information required for MIPS, as well as fitting into a number of guidelines.

Effective immediately, qualifying providers and groups may apply for certain exceptions in order to meet the program requirements.

Who can apply for these flexibilities?
Clinicians who have not been able to collect and record MIPS-required data due to the pandemic are on the front line to be eligible for the MIPS Extreme and Uncontrollable Circumstances Exception. Individual Clinicians, Groups, may submit an Extreme & Uncontrollable Circumstances Application to reweight ANY or ALL MIPS performance categories.

Are healthcare providers automatically considered for the exception?
No, the reweight due to PHE COVID-19 is not awarded on an automatic basis.

What needs to be done?
Clinicians would have to keep written proof of a pandemic-related impact on file (this information is crucial for data validation or audit by CMS), and the application needs to be submitted. The decision to apply should be based on the practice's actual strong need and has to be carefully reviewed before applying. Failure to do so may result in application denial or future audits.

The application will be opened up until December 31, 2020.
CMS will consider both the circumstances and timing in order to evaluate the ability of an eligible provider to submit/collect data for each performance category selected in the application.
For example, the performance period for an improvement activity is an on-going 90-day period. In contrast, the performance period for Quality performance category is one calendar year, so an issue lasting for three months may have a greater impact on the availability of data collection for the Quality performance category than the provider’s ability to perform and attest to improvement activities.
In cases, providers report both an exception and data, the performance will be scored based on the data submitted rather than the exception.

Reminder!
Eligible providers who do not participate in this program will be subject to a negative payment adjustment of 9% in 2022. This percentage, if measured in dollar amount, is quite significant!

Have questions? We Can Help you surf through the rules and guidelines of MIPS as quickly as possible.