CMS Makes QPP Hardship Exception for COVD-19 Automatic in Most Cases for Reporting Year 2021

The Centers for Medicare & Medicaid Services (CMS) announced that they will apply the Quality Payment Program’s (QPP) “extreme and uncontrollable” circumstances hardship exception to most providers for the 2021 reporting year in a posting on their QPP webpage on November 10, 2021.  This means that providers would not have to apply on the QPP webpage for a hardship exception.  There would be no penalty or bonus for the vast majority of providers.   They stated:

“We’re applying the MIPS automatic extreme and uncontrollable circumstances policy to all individual MIPS eligible clinicians for the 2021 performance year …”

In the accompanying Fact Sheet in the QPP “Resource Library” entitled “Quality Payment Program COVID-19 Response”, CMS also states:

“Individually eligible clinicians will automatically have all performance categories reweighted to 0% and … [this] will result in a neutral payment adjustment (neither a positive nor a negative adjustment) for the 2023 MIPS payment year unless:

• The clinician submits data as an individual for 2 or more MIPS performance categories (Quality, Improvement Activities, and/or Promoting Interoperability);
  • Data submission by individual clinicians voids the 0% performance category weight on a category-by-category basis.
• The clinician is part of a group or APM Entity that submits data on behalf of its clinicians, resulting in a higher final score; or
• The clinician is part of a virtual group.

Under the automatic EUC policy, the cost performance category will always be weighted at 0%, even if you submit data as an individual for the other performance categories.”

This means that, because of budget neutrality provisions built into QPP and the Merit-Based Incentive Payment System (MIPS), there will be far fewer penalties in 2021 – and as a result, significantly fewer bonuses for the payment year 2023.

We are available and happy to assist you with issues related to eye care coding and reimbursement.  We are available to present our webinars related to the significant changes for 2022 QPP/MIPS and the 2021 Evaluation and Management eye exam coding.  This new full program includes a large, completely revised text and new Office Visit Guide pocket guides, so contact us if you are interested.  Stay safe.

www.corcoranccg.com (800) 399-6565