A recent article by RevCycleIntelligence reported that CMS will consider applying an automatic exception to some individual eligible clinicians and group practices. The key to getting the exception is for the clinicians who have not submitted data for at least two performance indicators.
CMS will identify individual MIPS eligible clinicians and they will receive a neutral payment adjustment in 2022, according to the announcement sent via email on Feb. 25, 2021.
The automatic exception policy, however, will not apply automatically to MIPS eligible clinicians who submit 2020 performance data as an individual in two or more performance categories or whose practice reports as a group.
Group participation in MIPS is optional and individual MIPS eligible clinicians within a practice will qualify for the automatic exception policy if the practice is unable to submit 2020 performance period data as a group, CMS clarified.
In this case, CMS will reweigh all four performance categories to zero percent, resulting in a neutral payment adjustment in 2020 unless, again, clinicians submit 2020 performance data as an individual in two or more performance categories or whose practice reports as a group by submitting data for one or more performance category.
CMS is also reopening the MIPS extreme and uncontrollable circumstances application for individual MIPS eligible clinicians, group, virtual groups, and Advanced Alternative Payment Models (APMs) entities through March 31, 2021 at 8:00 PM ET.
The agency is applying the exception policy more broadly in light of the ongoing COVID-19 pandemic, which continues to impact clinician performance.
The decline in volumes has put a significant strain on practices, with most performance measures falling well below 2019 levels by the start of 2021.
In particular, new patient visits—which are crucial to growing the practice—fell year-over-year and are likely to stay below expectations in the new year as communities adjust to changing COVID-19 numbers and slow vaccine rollouts, the firm stated.
This disruption to business caused by the ongoing pandemic has also had an impact on clinician performance in value-based reimbursement models like MIPS.
MIPS is a value-based reimbursement track under the Quality Payment Program that adjusts an eligible clinician’s Medicare payments based on performance across quality and cost metrics. The track specifically monitors clinician performance across four categories: Quality, Promoting Interoperability, Improvement Activities, and Cost.
CMS has been rolling out MIPS since 2017, adjusting the track to promote clinician participation. However, the emergence of COVID-19 last year has prompted the agency to enact more extreme adjustments to ensure clinicians are not penalized for performance during the unique 2020 performance period.
Eligible clinicians have also been able to apply for the extreme and uncontrollable circumstances policy to ensure they are not penalized for failing to submit or submitting incomplete data to CMS because of COVID-19.
Eligible clinicians who submitted data for two or three performance categories will receive a MIPS final score, as well as a payment adjustment in 2022, based on the data submitted and clinicians cannot submit an application to override the submitted data, CMS stated.
Groups and virtual groups that have submitted data to more than one performance category will also face a payment adjustment and cannot override their submitted data. However, those who have only submitted data for one performance category can apply to CMS to have the performance categories reweighted.
We believe that CMS is trying to work with eligible clinicians during a difficult 2020 pandemic year. Individual and group clinicians that were severely impacted by the pandemic, will avoid a penalty reimbursement reduction in 2022.