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MIPS Deadline Extended Due to COVID-19

The Centers for Medicare & Medicaid Services (CMS) has extended the 2019 Merit-based Incentive Payment System (MIPS) data submission deadline by 30 days, from March 31 to April 30, 2020. This is designed to provide relief to clinicians responding to the COVID-19 pandemic. In addition, the MIPS automatic "extreme and uncontrollable circumstances" policy will apply to MIPS-eligible clinicians who do not submit their MIPS data by the April 30, 2020 deadline.

Here are a few facts provided by CMS in the QPP Resource Library, to answer the most common questions clinicians might have during this time.GOP repeal effort threatens Medicaid users in MN, official says ...

What is the MIPS automatic extreme and uncontrollable circumstances policy?

Beginning with the 2017 performance period, CMS established an automatic extreme and uncontrollable circumstances policy in MIPS for clinicians affected by natural disasters and emergencies. Clinicians affected by these extreme and uncontrollable circumstances may have their performance categories reweighted and potentially receive a neutral payment adjustment.

What does the MIPS automatic extreme and uncontrollable circumstances policy for COVID-19 mean for me or my lab in the 2019 performance period?

CMS has determined that the MIPS automatic extreme and uncontrollable circumstances policy will apply to MIPS-eligible clinicians who do not submit their 2019 MIPS data by the April 30, 2020 extended deadline. If you are a MIPS-eligible clinician and do not submit any MIPS data by April 30, 2020, you won’t need to take any additional action to qualify for the automatic extreme and uncontrollable circumstances policy. You will be automatically identified and will receive a neutral payment adjustment for the 2021 MIPS payment year.
 
If no MIPS-eligible clinicians in an Alternative Payment Model (APM) Entity submit data for the Promoting Interoperability or Quality performance categories due to extreme and uncontrollable circumstances, the Cost performance category will be weighted at zero percent as usual and the Improvement Activities performance category will be scored as usual, but the APM Entity will be eligible to have the Promoting Interoperability and Quality performance categories reweighted to zero percent in accordance with §§ 414.1370 and 414.1375. If only one performance category (Improvement Activities) is scored, this would result in a neutral MIPS payment adjustment for MIPS eligible clinicians in the APM Entity.
 
Note: Many MIPS-eligible clinicians who submitted data in previous years received high scores in MIPS. MIPS-eligible clinicians who submit data by April 30, 2020 on two or more performance categories will be scored on those categories and receive a 2021 MIPS payment adjustment based on their 2019 MIPS final score. 
 

Who can I contact for more information?

Visit the QPP website, the QPP Resource Library, or the CMS Current Emergencies webpage.

You can subscribe to the QPP listserv for updates (scroll to the bottom of the QPP website to sign up). Contact the Quality Payment Program at 1-866-288-8292 or by email.