To avoid up to a 9% payment adjustment in 2022 on Medicare payments, MIPS eligible providers and groups must:
- Report data to CMS (in two or three performance categories) TO
- Earn a score of at least 45 points across two, three or four performance categories OR
- Apply for an exception!
If the COVID-19 pandemic and/or recent storms prevent a MIPS eligible clinician or group from collecting 2020 MIPS data, they can submit an application to have all, some or one of the MIPS performance scores reweighted to 0%. In turn, instead of a penalty (negative payment adjustment), an eligible clinician or group would receive a neutral or 0% payment adjustment in 2022.
In July, we reported that CMS opened the 2020 PI and Extreme and Uncontrollable Circumstances Exception Application window for the 2020 Performance Year and provided a link to the fact sheet. The fact sheet was updated in September. Below are a few highlights:
Extreme and Uncontrollable Exception
- For performance year 2020, as of now, there still are no CMS qualifying events that have been identified for automatic Extreme and Uncontrollable exceptions.
- At this time, neither the COVID-19 pandemic nor the severe weather is considered a CMS emergency for purposes of an automatic exemption.
This means that, unlike in 2019, if an eligible clinician wants an exception they have to apply.
- Eligible providers or groups can apply for an exception from the entire program (and receive a neutral adjustment) OR
- Eligible providers or groups can apply for an exception from just one or more of the performance categories (and possibly still earn a positive payment adjustment – greater than 0% if they properly report data in the remaining categories).
- Both the public health emergency and the recent hurricanes are considered extreme and uncontrollable circumstances and can be referenced and used for reasons that would limit QPP participation.
- The impact of these events may have resulted in circumstances that inhibited or significantly impacted a provider or group’s ability to submit data:
- Staffing challenges
- Financial struggles
- Supply issues
- Patient flow issues
- Facility and utility issues
- The application does not require documentation or “proof” of the circumstances. However, retain documentation for your own records and for data validation or audit purposes.
- The online application is very easy and straightforward. It can be completed in less than 15 minutes.
- Most providers are receiving decisions back within 24 hours of submitting applications.
- The deadline for the application is December 31, 2020.
- Applications must be submitted through the QPP portal using a HARP account.
- Eligible clinicians, groups or their (practice staff) representatives can contact the QPP Help Desk for assistance and step-by-step guidance through the exception application process.
APM Qualified Participants … Don’t miss out on your 5% bonus payment!
Quality Payment Program APMs: Update Billing Information by November 13, 2020
Many Qualifying Alternative Payment Model (APM) Participants (QPs) received 2020 5% APM incentive payments last month. Some clinicians need to update their Medicare billing information by November 13, 2020, to get paid.
Do you need to verify your Medicare billing information?
- If you didn’t get paid, find your name on the spreadsheet to find out which form(s) to send to CMS. Log in to the QPP website using your HARP credentials to update your billing information; see detailed instructions.
- If you got paid, you don’t need to do anything.
- For more information:
IMPORTANT NOTE: If an eligible clinician or group is granted the exception, but then submits data, the data submission will override the re-weighting 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 questions about this and the Promoting Interoperability Exception application, or general QPP guidance, contact LAMMICO Practice Management Specialist, Natalie Cohen, MBA, MHA, at 504.841.2727 or firstname.lastname@example.org.