In 2020, the SARS-CoV-2 pandemic, hurricanes in the Gulf of Mexico and wildfires in the Western U.S., have all created challenging circumstances for clinicians to meet federal reporting requirements. To accommodate these difficulties, the Centers for Medicare & Medicaid Services (CMS) have provided the opportunity to apply for exceptions for the Performance Year (PY) 2020 Quality Payment Program (QPP) Merit-Based Incentive Program (MIPS) program requirements.
Two exception applications are available to clinicians in PY2020: The Extreme and Uncontrollable Circumstances Exception and the MIPS Promoting Interoperability Performance Category Hardship Exception. The applications for both exceptions are currently open and will close Dec. 31, 2020.
The Extreme and Uncontrollable Circumstances Exception allows clinicians to request reweighting for any or all performance categories if they encounter a circumstance deemed extreme and uncontrollable or a public health emergency outside their control. Thus, this exception includes practices affected by the pandemic. According to the CMS, appropriate circumstances would be those that:
- Prevent providers from collecting information necessary for a MIPS performance category;
- Prevent submission of information that would be used to score a MIPS performance category for an extended period of time (e.g., if you were unable to collect data for the quality performance category for three months); and/or
- Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.
Qualifying circumstances for this exception include the COVID-19 pandemic and wildfires.
The MIPS Promoting Interoperability Performance Category Hardship Exception allows clinicians to request that the MIPS Promoting Interoperability performance category be reweighted to 0%. This exception is available to MIPS-eligible clinicians, groups and virtual groups that can cite one of the following reasons:
- It’s a small practice;
- It has decertified electronic health record technology;
- It has insufficient Internet connectivity;
- It faces extreme and uncontrollable circumstances, such as disaster, practice closure, severe financial distress or vendor issues; or
- It lacks control over the availability of certified electronic health record technology.
For more detailed information on the CMS’ QPP exception, see the Applications Fact Sheet.