Due to COVID-19 CMS will be accepting exceptions that allow MIPS eligible clinicians, groups, and virtual groups, Qualifying Providers (QPs) for the purpose of this article, to submit an application requesting reweighting of one or more MIPS performance categories to 0%. Exception applications are due Dec 31, 2020. In certain circumstances, MIPS performance category reweighting may be applied automatically.
There are two applications for QPs to consider:
Extreme and Uncontrollable Circumstances Exception Application. This application allows you to request reweighting for any or all MIPS performance categories if you encounter an extreme and uncontrollable circumstance or public health emergency, such as COVID-19, that is outside of your control.
QPs groups can submit an application to have their MIPS Quality, Cost, Improvement Activities, and/or Promoting Interoperability performance categories reweighted to 0% if:
- they experience an extreme and uncontrollable circumstance outside of their control, such as a natural disaster or public health emergency (PHE) (e.g. COVID-19 pandemic), that prevents them from collecting data for an extended period of time, or that could impact their performance on cost measures.
MIPS Promoting Interoperability Performance Category Hardship Exception Application. This application allows you to request reweighting specifically for the Promoting Interoperability performance category if you qualify for one of the listed exceptions.
MIPS Promoting Interoperability Hardship Exception Applications allow QPs to request that QPs’ MIPS Promoting Interoperability performance category be reweighted to 0% if QPs:
- are a small practice
- have decertified EHR technology
- have insufficient Internet connectivity
- face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
- lack control over the availability of CEHRT
Lacking 2015 Edition CEHRT does not qualify as a reason to submit an application.
Please keep in mind that regardless of what Exception Application is completed QPS are not required to submit documentation supporting their case with their application. However, it is extremely important that any QP submitting an application retain such support documentation in the event they are selected by CMS for data validation or audit.
Applications are due December 31, 2020, 8 p.m. ET and they must reference COVID-19 as the extreme and uncontrollable circumstance affecting them.
For more information, you can download the 2020 Quality Payment program Exception Fact Sheet at the EPI Conferences website (www.epiconferences.com) or visit the CMS Quality Payment Program web site at https://qpp.cms.gov/mips/quality-measures.