CMS offering automatic 2020 MIPS exemption

March 10, 2021

Due to Covid-19, CMS has announced it will automatically extend its extreme and uncontrollable circumstances policy to all 2020 Merit-based Incentive Payment System (MIPS) clinicians who have only submitted limited data.

Previously, individuals and groups impacted by the Covid Public Health Emergency in 2020 had the opportunity to apply by Feb. 1 to have one or all of their MIPS categories reweighted to zero, meaning they would receive a neutral Medicare payment adjustment in the corresponding 2022 payment year. However, CMS is electing to re-open the application period for those who have already submitted some data and apply a blanket exception for anyone who has not yet submitted 2020 data.

Individuals who have submitted no data or have only submitted data for one category (such as claims-based Quality submissions) will automatically be exempted from the program. However, individuals who have submitted data for two or more categories will be scored in those categories and are not eligible to apply for an exemption.

Groups who have already submitted data in one category must complete an exception application by 8 p.m. March 31 in order to request reweighting of one or all of their MIPS categories. Groups who have already submitted data in two or more categories are not eligible to apply for an exception at this point and will be scored on all categories they are eligible for.

APM Entities participating in MIPS APMs can submit an EUC application with some differences from the MIPS EUC policy for individuals, groups, and virtual groups:

  • APM Entities are required to request reweighting for all performance categories.
  • More than 75% of the MIPS eligible clinicians in the APM Entity must be eligible for reweighting in the Promoting Interoperability performance category.
  • Unlike applications for individuals, groups and virtual groups, an APM Entity’s approved application for performance category weighting will override previously submitted data.

If an APM Entity doesn’t report for the 2020 performance period (or doesn’t have an approved EUC application), their MIPS eligible clinicians will receive a negative payment adjustment in the 2022 payment year.

2020 MIPS participants will see penalties of up to +/-7% of their 2022 Medicare Part B payments.

Below is the summary included in CMS’s press release:

Individual clinicians, groups, and virtual groups that haven’t submitted data.

  • Individual MIPS eligible clinicians: You don’t need to take any additional action to qualify for the automatic EUC policy. You will be automatically identified and will receive a neutral payment adjustment for the 2022 MIPS payment year unless 1) you submit data as an individual in 2 or more performance categories, or 2) your practice reports as a group, by submitting data for one or more performance category.
  • Groups: You don’t need to take any further action if you’re not able to submit data for the 2020 performance period. Group participation is optional, and your individual MIPS eligible clinicians qualify for the automatic EUC policy. They will have all 4 performance categories reweighted to 0% and receive a neutral payment adjustment for the 2022 MIPS payment year unless 1) they submit data in 2 or more performance categories as individuals, or 2) the practice reports as a group, by submitting data for one or more performance category.
  • Virtual Groups: If you’re unable to submit data for the 2020 performance period, you must submit an EUC application for all 4 performance categories by the deadline.

Individual clinicians, groups, and virtual groups that have submitted data.

  • Individual MIPS eligible clinicians that have submitted data for a single performance category (such as Medicare Part B Claims measures submitted throughout the 2020 performance period):
    • You don’t need to take any additional action to be eligible for the automatic EUC policy.
    • You’ll be automatically identified and have all 4 performance categories reweighted to 0% and will receive a neutral payment adjustment for the 2022 MIPS payment year unless 1) you submit data for another performance category, or 2) your group submits data for one or more performance category.
  • Individual MIPS eligible clinicians that have submitted data as an individual for 2 or 3 performance categories:
    • You’ll receive a MIPS final score and MIPS payment adjustment for the 2022 MIPS payment year based on the data you’ve submitted.
    • You’ll only be scored in the performance categories for which data are submitted.
    • You can’t submit an application to override previously submitted data.
  • Groups and virtual groups that have submitted data for a single performance category:
    • If you’re not able to complete data submission for other performance categories, you can submit an application to request reweighting in all 4 performance categories.
    • This includes small practices that were automatically scored as a group on Medicare Part B Claims measures submitted throughout the 2020 performance period.
    • If you don’t submit an application, your group will be scored in all performance categories unless you are eligible for reweighting in one or more performance categories.
    • If your application is approved and data isn’t submitted for another performance category, your MIPS eligible clinicians will receive a neutral payment adjustment for the 2022 MIPS payment year.
  • Groups and virtual groups that have submitted data for 2 or 3 performance categories:
    • Your MIPS eligible clinicians will receive a MIPS final score and MIPS payment adjustment for the 2022 MIPS payment year.
    • Your group will be scored in all performance categories unless you qualify for reweighting in one or more performance categories.
    • You can’t submit an application to override previously submitted data.

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