CMS Update: Doctors and Clinicians Preview Period is Now Open; 2020 MIPS Extreme and Uncontrollable Circumstances Exception Application Deadline for COVID-19 Extended to February 1, 2021

CMS provided the following update on January 25, 2021:

Doctors and Clinicians Preview Period is Now Open

The Doctors and Clinicians Preview Period is officially open as of January 25, 2021 at 10 a.m. ET (7 a.m. PT). You can now preview your 2019 Quality Payment Program (QPP) performance information before it will appear on clinician and group profile pages on Medicare Care Compare and in the Provider Data Catalog (PDC). You can access the secured Preview through the QPP website.

Please refer to the resources below on how to preview your information:

To learn more about the 2019 QPP performance information that is available for preview as well as the 2018 clinician utilization data that will be added to the PDC, download these documents from the Care Compare: Doctors and Clinicians Initiative page:

Accountable Care Organizations (ACOs) can preview their performance information via their 2019 MIPS Performance Feedback Reports. A list of ACO performance information targeted for public reporting is available on the Care Compare: Doctors and Clinicians Initiative page.

The Preview Period will close on March 25, 2021 at 8 p.m. ET (5 p.m. PT).

Please note the 2019 QPP performance information is targeted for public reporting in 2021 and will be added to Care Compare and/or the PDC after all Targeted Reviews are completed. If you have an open Targeted Review request, you will still be able to preview your 2019 Quality Payment Program performance information during the Doctors and Clinicians Preview Period.

If you have any questions about public reporting for doctors and clinicians or the Doctors and Clinicians Preview Period, please contact [email protected].

2020 MIPS Extreme and Uncontrollable Circumstances Exception Application Deadline for COVID-19 Extended to February 1, 2021

Reminder: To further support clinicians during the COVID-19 public health emergency, the Centers for Medicare & Medicaid Services (CMS) extended the deadline for COVID-19 related 2020 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances Exception applications to February 1, 2021.

For the 2020 performance year, CMS will be using its Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency.

If you have any concerns about the effect of the COVID-19 public health emergency on your performance data, including cost measures, for the 2020 performance period, submit an application now and be sure to cite COVID-19 as the reason for your application.

If you have an approved application, you can still receive scores for the Quality, Improvement Activities and Promoting Interoperability performance categories if you submit data. If the Cost performance category is included in your approved application, you will not be scored on cost measures even if other data are submitted.

IMPORTANT: Individuals, groups and virtual groups can’t submit an application to override PY2020 data that has already been submitted.  Any data submitted as an individual, group or virtual group before or after an application has been approved will be scored.  Learn more in the 2020 Exceptions Applications Fact Sheet.

Note: The deadline to submit a MIPS Promoting Interoperability Performance Category Hardship Exception application or an Extreme and Uncontrollable Circumstances application not related to COVID-19 was December 31, 2020.

How do I Apply?

You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself, or another MIPS eligible clinician, group, virtual group or APM Entity. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you register for a HARP account, sign in to qpp.cms.gov, select “Exceptions Applications” on the left-hand navigation, select “Add New Exception,” and select “Extreme and Uncontrollable Circumstances Exception” or “Promoting Interoperability Hardship Exception.”

How do I Know if I’m Approved?

If you submit an application for either of the exceptions, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool.

For APM Entities Only

In the 2021 Medicare Physician Fee Schedule (PFS) Final Rule, the Centers for Medicare & Medicaid Services (CMS) finalized its previous proposal to allow Alternative Payment Model (APM) Entities to submit an application to reweight Merit-based Incentive Payment System (MIPS) performance categories as a result of extreme and uncontrollable circumstances. In addition, CMS extended the application deadline for COVID-19 to February 1, 2021.

If an APM Entity’s application is approved, that APM Entity will receive a final score equal to the performance threshold for the 2020 MIPS performance year, and the MIPS eligible clinicians in the APM Entity group would receive a neutral payment adjustment in 2022.

Who is Eligible to Submit an Application?

APM Entities affected by extreme and uncontrollable circumstances in the following models are able to submit an application:

  • Medicare Shared Saving Program (SSP)
  • Next Generation ACO Model
  • Vermont Medicare ACO Model
  • Comprehensive Primary Care Plus (CPC+)
  • Comprehensive ESRD Care (CEC)
  • Bundled Payments for Care Improvement (BPCI)
  • Oncology Care Model (OCM)
  • Maryland Primary Care Program
  • Independence at Home Demonstration

What are the Application Requirements?

Unlike those who choose to apply as individual clinicians, groups, or virtual groups, APM Entities must apply to reweight all MIPS performance categories to 0%. Additionally, 75% of the MIPS eligible clinicians in the APM Entity must qualify for reweighting in the MIPS Promoting Interoperability performance category. They may qualify automatically or through a MIPS Promoting Interoperability Hardship Exception Application (previously due December 31, 2020).

CMS does not require APM Entities to submit documentation with their applications. However, APM Entities should retain documentation of the circumstances supporting their application for their own records in the event they are selected by CMS for data validation or an audit.

Will Submitting Data Void the Exception?

Data submitted for an APM Entity will not override performance category reweighting from an approved application. This differs from the policy for individual, group, and virtual group applications.

Will an Approved Application Affect Model-Specific Reporting Requirements?

If an APM Entity’s application is approved, the approval would only affect MIPS reporting, and that APM Entity would still be required to meet its model-specific reporting requirements.

For More Information

Questions?

Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: [email protected]. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.

  • Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

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