If a devastating hurricane buries your office computer in toxic flood waters, or relocates your clinic's roof to a field full of bewildered cows, the last thing on your mind is going to be ― or at least, should be ― reporting data for government quality programs.
TMA understands that, and fortunately, the Centers for Medicare & Medicaid Services (CMS) does, too.
At TMA's request, CMS announced in December that physicians in areas affected by Hurricane Harvey will not be required to participate in the Quality Payment Program's (QPP's) Merit-Based Incentive Payment System (MIPS) for 2017. Thus, those physicians won't incur a 4-percent Medicare payment cut in 2019.
TMA estimates the MIPS exception could affect roughly 27,000 Texas physicians who practice in the affected counties and accept Medicare patients. That estimate is based on data from the TMA 2016 Physician Survey and from September 2017 Texas Medical Board county physician counts.
David Teuscher, MD, regional director of U.S. Department of Health and Human Services (HHS) Region VI, which includes Texas, says TMA was instrumental in identifying the problems that affected physicians faced.
We wanted to “give people a break at this point in time," Dr. Teuscher said. "Because this is the first reporting period, and you want to get it right. And if you don't have the resources readily available, if you're distracted digging out from a hurricane or trying to help others who have been more affected [to] come into practice with you, then you're really not in a position to comply."
Note that the extreme and uncontrollable circumstances policy doesn't apply just to practices Harvey tore apart. If you're in one of 53 affected Texas counties designated by the Federal Emergency Management Agency, you're exempt from 2017 MIPS participation, regardless of whether Harvey physically damaged your practice ― simple as that.
The policy applies only to individual MIPS clinicians in affected areas. However, David Nilasena, MD, chief medical officer for HHS Region VI, says physician groups in the affected counties can take advantage of the policy by simply doing nothing.
"The way you indicate you're reporting as a group is by sending in some data as a group. So if you don't send in any data, we assume you're reporting as individuals or that you want to be assessed as individuals," Dr. Nilasena said. "So what that means is that if you're a group in one of these affected counties and you don't do anything, then we will look at each individual and grant them the appropriate exception."
For more details, check out the CMS fact sheet for the MIPS Extreme and Uncontrollable Circumstances Policy.
Physicians who participate in the QPP do so either through MIPS or an alternative payment model (APM). CMS also has released an interim final rule that provides a separate hurricane-related hardship policy for Medicare Shared Savings Program accountable care organization APMs.