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MIPS Exceptions and Cost Category weighting for 2019 reporting year clarified by CMS

Recently, CMS extended the deadline for QPP and MIPS submissions for the 2019 Performance Year to April 30, 2020.  We reported on that in a previous webnews.  Since then, CMS has clarified some of the information and re-opened the Exception Application window.

The new information is available on the QPP Exceptions webpage, CMS noted the following:

 “… we are extending the automatic MIPS Extreme and Uncontrollable Circumstances policy to individual clinicians and re-opening the Extreme and Uncontrollable Circumstances Exception application for MIPS eligible clinicians, groups and virtual groups, including those who have already submitted data …

In the new clarification CMS notes, “If you are a MIPS eligible clinician in a practice that has already submitted data as a group, we will score the group in all performance categories according to existing MIPS scoring policies. You will receive a final score and payment adjustment based on the data submitted.”  If you began submission of 2019 data (as an individual or group) but did not finish or cannot be sure it is complete, it was previously unclear if CMS would take your data as “submitted” and score you accordingly.  In the new information, CMS published a “Quality Payment Program COVID-19 Response Fact Sheet” which can be accessed via the QPP Exceptions webpage link above.  The Fact Sheet notes if you did “… not submit data as an individual in two or more performance categories by April 30, 2020, you won’t need to take any additional action to qualify” and CMS can automatically identify you.  APM (Alternative Payment Model) and other types of submitters have slightly different rules but even those are relaxed.  If you did submit data but are not sure that it is complete, you can still apply for this Exception.

Importantly, in the new information, CMS also notes that by triggering the “… automatic extreme and uncontrollable circumstances policy, the Cost performance category will always be weighted at 0%, even if you submit data for the other performance categories.”  That means most providers will have their 2019 Cost/Resource Use score re-weighted even if they are confident of their submissions in the other three MIPS categories and choose not to apply for this Exception.

For directions on the application, use the Exceptions link above and scroll to the area titled “How do I Apply?” and follow the 4-step directions.  The application itself is accessible here.  Importantly, the Application is only open until 8 PM (Eastern) on April 30, 2020.  CMS notes:  “If your application is approved, all 4 performance categories will be re-weighted and [result in] … a neutral payment adjustment for the 2021 payment year.”

We are available and happy to assist you with claims issues, telemedicine questions, and other topics related to eye care during this public health emergency.  Stay safe.

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