CMS Delays MIPS and Automatically Applies Hardship Exemption for Non-Submission

We previously shared that the MIPS program could be suspended or otherwise delayed. Today, CMS officially announced a delay to MIPS 2019 reporting which extends the deadline for 2019 MIPS data submission from March 31, 2020 to April 30, 2020. Along with the delay to MIPS reporting, they will be automatically applying the “extreme and uncontrollable circumstances policy exception” to anyone who chooses not to submit MIPS 2019 data. This basically means that you have another month to submit your MIPS 2019 data if you’d like to participate, but that if you don’t submit any data, you’ll avoid any MIPS penalties.

As far as MIPS 2020 data submission, they said, “CMS is evaluating options for providing relief around participation and data submission for 2020.” I imagine there’s more relief coming from CMS when it comes to MIPS 2020, but it’s probably wise for them to see how things evolve over the next few months before they pull the trigger on what relief is best for MIPS 2020 reporting.

On the hospital side of things, CMS has made submission of Q4 2019 data optional. If a hospital doesn’t submit that data, they’ll calculate the performance based on the Q1-Q3 data. They’ve also said that they will not count data for the first two quarters of 2020 and no data needs to be submitted to CMS for this time period.

Here are the full details on MIPS and other quality reporting delays announced by CMS today:

CMS Announces Relief for Clinicians, Providers, Hospitals and Facilities Participating in Quality Reporting Programs in Response to COVID-19

The Centers for Medicare & Medicaid Services (CMS) is supporting clinicians on the front lines by getting red tape out of the way so the healthcare delivery system can focus on the 2019 Novel Coronavirus (COVID-19) response. CMS is implementing additional extreme and uncontrollable circumstances policy exceptions and extensions for upcoming quality measure reporting and data submission deadlines for the following CMS programs:

Provider Programs 2019 Data Submission 2020 Data Submission

Quality Payment Program -Merit-based Incentive Payment System (MIPS)

Deadline extended from March 31, 2020 to April 30, 2020.

MIPS eligible clinicians who have not submitted any MIPS data by April 30, 2020 will qualify for the automatic extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year.

CMS is evaluating options for providing relief around participation and data submission for 2020.
Medicare Shared Savings Program Accountable Care Organizations (ACOs)

Hospital Programs 2019 Data Submission 2020 Data Submission
Ambulatory Surgical Center Quality Reporting Program

Deadlines for October 1, 2019 – December 31, 2019 (Q4) data submission optional.

If Q4 is submitted, it will be used to calculate the 2019 performance and payment (where appropriate). If data for Q4 is unable to be submitted, the 2019 performance will be calculated based on data from January 1, 2019 – September 30, 2019 (Q1-Q3) and available data.

CMS will not count data from January 1, 2020 – June 30, 2020 (Q1-Q2) for performance or payment programs. Data does not need to be submitted to CMS for this time period.

* For the Hospital-Acquired Condition Reduction Program and the Hospital Value-Based Purchasing Program, if data from January 1, 2020 – March 31, 2020 (Q1) is submitted, it will be used for scoring in the program (where appropriate).

CrownWeb National End-Stage Renal Disease (ESRD) Patient Registry and Quality Measure Reporting System
ESRD Quality Incentive Program
Hospital-Acquired Condition Reduction Program
Hospital Inpatient Quality Reporting Program
Hospital Outpatient Quality Reporting Program
Hospital Readmissions Reduction Program
Hospital Value-Based Purchasing Program
Inpatient Psychiatric Facility Quality Reporting Program
PPS-Exempt Cancer Hospital Quality Reporting Program
Promoting Interoperability Program for Eligible Hospitals and Critical Access Hospitals

Post-Acute Care Programs 2019 Data Submission 2020 Data Submission
Home Health Quality Reporting Program

Deadlines for October 1, 2019 – December 31, 2019 (Q4) data submission optional.

If Q4 is submitted, it will be used to calculate the 2019 performance and payment (where appropriate).

Data from January 1, 2020 – June 30, 2020 (Q1-Q2) does not need to be submitted to CMS for purposes of complying with quality reporting program requirements.

Home Health and Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey data from January 1, 2020 through September 30, 2020 (Q1-Q3) does not need to be submitted to CMS.

*For the Skilled Nursing Facility (SNF) Value-Based Purchasing Program, qualifying claims will be excluded from the claims-based SNF 30-Day All-Cause Readmission Measure (SNFRM; NQF #2510) calculation for Q1-Q2.

Hospice Quality Reporting Program
Inpatient Rehabilitation Facility Quality Reporting Program
Long Term Care Hospital Quality Reporting Program
Skilled Nursing Facility Quality Reporting Program
Skilled Nursing Facility Value-Based Purchasing Program

CMS is granting exceptions and extensions to assist healthcare providers and suppliers while they direct their resources toward caring for their patients and ensuring the health and safety of patients and staff. For those programs with data submission deadlines in April and May 2020, submission of those data will be optional based on the facility’s choice to report. In addition, no data reflecting services provided January 1, 2020-June 30, 2020 will be used in CMS’s calculations for the Medicare quality reporting and value-based purchasing programs in order to reduce providers’ data collection and reporting burden as they are responding to the COVID-19 pandemic.

CMS recognizes that quality measure reporting may not be reflective of performance for measures such as cost, readmissions and patient experience during this time of emergency and seeks to hold organizations harmless for data during this period. CMS will continue to monitor the situation and adjust reporting periods and submission deadlines accordingly. More detailed information about changes to each of these quality reporting programs will be provided soon.

Quality Payment Program

2019 MIPS Submission Deadline Extended: Submit 2019 Data by April 30, 2020

The 2019 MIPS data submission deadline will be extended by 30 days to April 30, 2020. If you have already submitted MIPS data or if you submit MIPS data by April 30, 2020, you will be scored and receive a MIPS payment adjustment based on the data you submit. Many MIPS eligible clinicians have performed very well in the MIPS program in previous years. If you need to revise any data that has already been submitted you can still make changes by logging into qpp.cms.gov by the new deadline.

2019 MIPS Automatic Extreme and Uncontrollable Circumstances Policy Update

MIPS eligible clinicians who have not submitted any MIPS data by April 30, 2020 do not need to take any additional action to qualify for the automatic extreme and uncontrollable circumstances policy. These clinicians will be automatically identified and receive a neutral payment adjustment for the 2021 MIPS payment year. All four MIPS performance categories for these clinicians will be weighted at zero percent, resulting in a score equal to the performance threshold, and a neutral MIPS payment adjustment for the 2021 MIPS payment year. However, if a MIPS eligible clinician submits data on two or more MIPS performance categories, they will be scored and receive a 2021 MIPS payment adjustment based on their 2019 MIPS final score.

CMS will continue monitoring the developing COVID-19 situation and assess options to bring additional relief to clinicians and their staff so they can focus on caring for patients.

About the author

John Lynn

John Lynn

John Lynn is the Founder of the HealthcareScene.com, a network of leading Healthcare IT resources. The flagship blog, Healthcare IT Today, contains over 13,000 articles with over half of the articles written by John. These EMR and Healthcare IT related articles have been viewed over 20 million times.

John manages Healthcare IT Central, the leading career Health IT job board. He also organizes the first of its kind conference and community focused on healthcare marketing, Healthcare and IT Marketing Conference, and a healthcare IT conference, EXPO.health, focused on practical healthcare IT innovation. John is an advisor to multiple healthcare IT companies. John is highly involved in social media, and in addition to his blogs can be found on Twitter: @techguy.

3 Comments

Click here to post a comment
   

Categories