Apply by April 30 to Avoid a 7% MIPS Payment Penalty

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The data submission period for the Merit-Based Incentive Payment System (MIPS) under the 2019 Quality Payment Program (QPP) ends at 7 pm (CT) Thursday, April 30

However, because of COVID-19 you might qualify for an exception that would result in a neutral payment adjustment, meaning neither a MIPS bonus nor a 7% payment penalty in 2021. 

The Texas Medical Association encourages you to review updated guidance from the Centers for Medicare & Medicaid Services (CMS) and submit an “extreme and uncontrollable circumstances” application by the deadline, if needed. 

Last month, TMA informed physician members that CMS, in response to COVID-19, extended the MIPS deadline to April 30 from March 31. At the time, CMS reported that some MIPS-eligible clinicians who hadn’t submitted their 2019 data by April 30 would avoid the 7% MIPS payment penalty under the automatic extreme and uncontrollable circumstances policy that took effect due to the COVID-19 public health emergency declaration. 

The policy, however, is limited to individual MIPS-eligible clinicians and does not apply to group or virtual group participation under certain circumstances. In addition, MIPS alternative payment models (APMs) each have their own separate extreme and uncontrollable circumstances policies. 

Based on clinician feedback, CMS has since clarified policies and updated its QPP COVID-19 Response Fact Sheet for individual MIPS-eligible clinicians, groups, virtual groups, facility-based clinicians, and MIPS APMs. The agency also reopened the 2019 extreme and uncontrollable circumstances application for those who are unable to start or complete their 2019 data submission. 

The application is available for: 

  • Individual clinicians who started, but are unable to complete, their data submission;
  • Small practices that were automatically scored as a group on Medicare Part B claims quality measures;
  • Groups that started, but are unable to complete, their data submission;
  • Virtual groups that are unable to start or complete their data submission; and
  • Individual clinicians and groups eligible for facility-based measurement and who have already submitted data for one or more categories. 

An approved COVID-19 application will reweight performance categories to 0%, void previously submitted data, and result in a neutral payment adjustment in 2021. 

Physicians who participated in a Medicare Shared Savings Program Accountable Care Organization or other type of MIPS APM in 2019, and who are unable to complete their data submission due to COVID-19, should refer to their respective extreme and uncontrollable circumstances policies or have their APM administrators contact CMS to obtain accurate guidance. 

For complete details, refer to the QPP COVID-19 Response Fact Sheet. For questions, contact the QPP Service Center at (866) 288-8292 or by email at QPP@cms.hhs.gov. For QPP help, visit the TMA MACRA Resource Center.

Last Updated On

April 21, 2020

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