By Stephen Besch, Director of Clinical Quality Reporting
Between rising COVID cases, falling elective procedure volumes and tightening revenues, 2020 was certainly a challenging year for medical professionals across the nation. Fortunately, CMS recognizes that the extraordinary strain placed on many organizations may have negatively affected their performance under the Merit-based Incentive Payment System (MIPS). They are providing relief to clinicians and practices affected by these unique disruptions in the form of Extreme and Uncontrollable Circumstances (EUC) exceptions for 2020 MIPS reporting. CMS is offering two types of EUC exceptions – the first will be applied automatically, while the second must be explicitly requested.
If your facility’s ZIP code was on the FEMA federal disaster area list during 2020 (due to wildfires or hurricanes, for example), you will automatically qualify for an Extreme and Uncontrollable Circumstances exception for 2020 MIPS participation. These exceptions will encompass all four MIPS performance categories, resulting in a neutral payment adjustment for the affected clinician(s).
However, if the COVID-19 public health emergency adversely affected your MIPS performance in 2020, you must apply to CMS for a pandemic-related reporting exception. These exceptions can be requested for any number of performance categories. If an exception applies to one or two performance categories, their weights will be redistributed to the remaining categories in your final MIPS score. If an exception applies to more than two categories, you will automatically receive a neutral payment adjustment, as MIPS scores cannot be calculated from fewer than two performance categories. The deadline to submit applications for a pandemic-related exception is February 1, 2021.
You can still submit data for a category covered by a EUC exception. However, submitting data for a performance category that has already been assigned an exception will negate that category’s exception. And if an individual, group or virtual group submits data for two or more performance categories, they will receive a final MIPS score based on their performance in those categories.
For example, a clinician submitting data for two MIPS categories after receiving an automatic EUC exception will effectively waive their exception and become subject to MIPS payment adjustments once again.
With that provision in mind, it’s critical to know your status regarding any EUC exceptions before submitting any data. CMS typically notifies applicants for pandemic-related exceptions via email within a few days of receiving their request, but the QPP Participant Lookup Tool will display EUC status regardless of whether it is related to a requested exception or an automatic one.
CMS has not yet said whether it will offer pandemic-related EUC exceptions for 2021, so MIPS participants should continue working toward maintaining optimal metrics for the 2021 performance period. In the meantime, incurring a MIPS penalty for the 2020 performance period is one small worry that overworked healthcare professionals shouldn’t have to confront. If your organization was significantly affected by the COVID-19 public health emergency in 2020, we strongly encourage you to review the CMS materials explaining the application process and be sure to submit your application by February 1.
It’s also important to keep in mind that these exceptions are only one part of maximizing your quality scoring. MIPS penalties are now at a maximum and the performance thresholds to avoid financial losses continue to climb. Understanding the new regulations and keys to maximizing program success have never been more critical to protecting your revenue. To learn about the latest program updates and explore simple strategies to optimize your results, please see our recent educational webinar.