Submit 2020 Data Now to Avoid Medicare Pay Cut
By David Doolittle


If you participated in Medicare’s Quality Payment Program (QPP) under the Merit-Based Incentive Payment System (MIPS), the deadline to submit all data through the Centers for Medicare & Medicaid Services (CMS) QPP portal is March 31.

CMS is automatically applying the extreme and uncontrollable circumstances policy under the Merit-Based Incentive Payment System (MIPS) to ALL MIPS eligible clinicians regardless of whether those clinicians have submitted data for the 2020 performance period.

CMS is extending the deadline for groups, virtual groups, and Alternative Payment Model (APM) entities to submit an extreme and uncontrollable circumstances exception application to March 31, to request reweighting for MIPS performance categories.

Groups and eligible clinicians who submit data in at least two MIPS categories will override the hardship exception and will be eligible to earn a bonus from the exceptional performance bonus pool, or potentially be subject to a penalty of up to 9%. 

Among notable elements of MIPS for 2020:

  • The scoring threshold to earn a bonus payment is 45 points. A score of less than 45 points leaves a physician subject to a payment cut of up to 9%. 
  • The threshold to earn an additional bonus for exceptional performance is 85 points in 2020, up from 75 in 2019.   

Physicians can submit data by qualified registry, qualified clinical data registry, electronic health record, web interface, survey vendor, and/or self-attestation

However, because it takes more time for CMS to process claims data, the deadline to submit claims under the Quality performance category was March 1 (see chart below). 

Data Submission Method

Deadline to submit

Via claims:

March 1, 2021.

Via third-party data registry:

Consult your registry vendor for deadlines.

Via CMS portal: Mar. 31, 2021

If you participated in an Alternative Payment Model (APM) such as the Medicare Shared Savings Program or one of the CMS bundled payment programs in 2020, you most likely will be scored under the APM standard within MIPS. Contact your APM administrator for details and ask if you need to submit any MIPS data. 

For answers to your MIPS and APM questions, contact the QPP Service Center at (866) 288-8292 or by email at To avoid long wait times, call during non-peak hours, which are before 9 am and after 1 pm CT.

Last Updated On

March 23, 2021

Originally Published On

December 02, 2020

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