MIPS Exception Applications
The 2020 PI and Extreme and Uncontrollable Circumstances Exception Application Window is Now Open!
Promoting Interoperability (PI) is the latest rendition of the Meaningful Use program. The PI performance category, one of the four performance categories in the Quality Payment Program, rewards providers for employing and utilizing EHR technology in their practices.
Remember … you don't have to have an EHR to avoid a penalty or earn a positive adjustment or bonus.
The Promoting Interoperability exception does not exempt the provider/group from the MIPS program, it only reweights the PI category to the Quality category. Some MIPS eligible clinicians are considered Special Status Clinicians and will automatically have their PI Category weighted to zero.
If an eligible clinician or group submits an application, but then chooses to report PI data, the data submission will negate the exception application.
Applications must be submitted by December 31, 2020.
The Extreme and Uncontrollable Circumstances Exception Application does exempt the provider from MIPS reporting entirely.
The approved extreme and uncontrollable circumstances would be those that:
- Cause you to be unable to collect information necessary to submit for a MIPS performance category, and/or;
- Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the Quality performance category for 3 months), and/or;
- Impact your normal processes, affecting your performance on cost measures and other administrative claims measures
2019 Quality Measure Score Suppression
CMS notified providers that they are "suppressing" the scores for three of the reported Quality Measures from the 2019 performance year. They chose these measures which “ … significantly impacted by clinical guideline changes or other changes where we (CMS) believe that adherence to guidelines in the existing measures could result in patient harm or otherwise cause misleading results as to what is measured as good quality of care … ”
The measures being suppressed are:
- Measure 69: Hematology: Multiple Myeloma: Treatment with Bisphosphonates
- Measure 450: Trastuzumab Received By Patients With AJCC Stage I (T1c) – III And HER2 Positive Breast Cancer Receiving Adjuvant Chemotherapy
- Measure 110: Preventive Care and Screening: Influenza Immunization
The suppression means that CMS is NOT going to count the score earned for these three measure in the total Quality score for providers in 2019. However, to ensure providers are not "penalized" for reporting the measure(s), CMS will reduce the Quality performance score formula's DENOMINATOR by 10 points.
NOTE: Most providers’ achievement point totals (a.k.a. denominators) are 60, but some provider groups have a denominators of 70, or if reporting via the CMS Web Interface, 100 or 110. The denominator is the maximum number of points a provider can earn based on the number of measures they could have reported.
For reference, the formulas for calculating Quality are:
In the Federal Register, the U.S. Department of Defense announced that they will allow telephone, audio only telehealth when performed by Tricare authorized providers.
Per the Interim Final Rule the effective date is May 12, 2020, through the end of the national emergency. The Humana Military website has not yet been updated when this LAMMICO news article was posted.
Payor Online Trainings Available
Blue Cross Blue Shield of Louisiana hosted an online provider training course on Wednesday, May 27 from 2-4 p.m. Topics included: credentialing, telehealth and authorizations.
UnitedHealthcare Bi-Weekly Virtual Town Halls were held June 2 and June 18. Topics included: telehealth, prior authorization and CARES Act provider relief.
This content is accurate as of May 22, 2020.