To what extent has the COVID-19 pandemic affected the MIPS program?

A Changing Landscape

Just as practices were preparing to submit their 2019 Performance Year MIPS data, the COVID-19 pandemic hit hard. Alongside the rest of the healthcare industry, COVID has disrupted the playing field.

In response, on March 22nd CMS announced the extension of the annual reporting deadline from March 31st to April 30th. Alongside that extension came a decision that MIPS eligible clinicians who had not submitted any data by that date would qualify for the “Extreme and Uncontrollable Circumstances Policy”. They would receive a neutral payment adjustment for 2021 MIPS Payment Year instead of the penalty that often accompanies a failure to report.

Extreme and Uncontrollable Circumstances Policy

As we turn to 2020, there have been multiple options that have offered clinicians flexibility for the 2020 performance year and beyond. One of those options is the Extreme and Uncontrollable Circumstances policy. This policy addresses “circumstances MIPS eligible clinicians may face as a result of widespread catastrophic events affecting a region or locale…” (CMS 2017).

For the COVID pandemic, this policy allows clinicians, groups and virtual groups are able to submit applications requesting the re-weighting of one or more MIPS performance categories. This application, found here, will remain open through December 31, 2020. For now, it only applies to individuals, groups or virtual groups, but they are exploring options for APMs as well.

COVID-19 Clinical Trials Improvement Activity

A new, high-weighted COVID-19 Clinical Trials (IA_ERP_3) improvement activity was added for the 2020 performance period, giving clinicians an opportunity to receive credit in MIPS for a lot of the vital work that is happening across the country to learn more about this virus. To receive credit, MIPS eligible clinicians or groups:

• May participate in a COVID clinical trial and have that data entered into a platform for the study
• If participating in the care of COVID-19 patients, may submit clinical COVID data to a clinical data registry for future study opportunities.

If paired with the existing improvement activity Participation in a 60 Day or Greater Effort to Support Domestic or International Humanitarian Needs (IA_ERP_2), full credit for this particular category can be achieved.

Set Yourself Up for Success

It is important now, more than ever, to invest in your practice’s MIPS program. With even more energy now directed at taking care of your practice and your community during this pandemic, we can help keep a solid pulse on your MIPS program. The Extreme and Uncontrollable Circumstances policy provides an opportunity to simplify reporting for the 2020 performance year, but to position yourself for success you need to think long-term. This program, while constantly undergoing change, appears to be here to stay. We can help you to settle on the best strategy to achieve optimal results for MIPS. We know the ins and outs of the program and know how to position you for success. Don’t leave points on the table in 2020, let us help!