KENTUCKY REGIONAL EXTENSION CENTER

UPDATED APRIL 3, 2020
On Sunday March 22, 2020, Centers for Medicare and Medicaid (CMS) announced relief for Clinicians, Providers, Hospitals and Facilities participating in Quality Reporting Programs as a response to COVID-19.

These relief efforts include the extension of the deadline for the Quality Payment Program reporting from March 31, 2020, to April 30, 2020. In addition to the extension of the deadline for the quality reporting program (includes MIPS & APM tracks), CMS also extended the criteria and approach for hardships. MIPS eligible clinicians who have not submitted any MIPS data by April 30, 2020, will automatically qualify for the extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year. CMS further clarified that any MIPS EC who submits two or more performance categories will be evaluated as normal under the program.

THE GOOD NEWS: this change provides those participating in the Quality Payment Program extensive flexibility. Should you have any questions around how this can impact your practice, please contact your Kentucky REC advisor or call us at 859-323-3090.

Please see below for an overview of the changes for the Quality Payment Program:

Provider Programs2019 Data Submission2020 Data Submission
Quality Payment Program - Merit-based Incentive Payment System (MIPS)Deadline extended from March 31, 2020 to April 30, 2020.

MIPS eligible clinicians who have not submitted any MIPS data by April 30, 2020 will qualify for the automatic extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year.
CMS is evaluating options for providing relief around participation and data submission for 2020.
Medicare Shared Savings Program Accountable Care Organizations (ACOs)

The 2019 MIPS Extreme and Uncontrollable Circumstances Policy Update is for MIPS Eligible Clinicians who HAVE NOT SUBMITTED any data for the 2019 MIPS program. No additional action is necessary to qualify for this policy. Clinicians will be automatically identified, and those meeting this policy will receive a neutral MIPS payment adjustment during the 2021 MIPS payment year. CMS has updated the QPP Participation Status Tool so Eligible Clinicians can see if the policy has been automatically updated.

For MIPS Eligible Clinicians and/or Groups who have started, but have not been able to complete their submission, and Virtual Groups that are unable to start or complete their submission, then an APPLICATION for the MIPS Extreme and Uncontrollable Circumstances must be submitted by April 30, 2020.

PLEASE NOTE: If data is submitted for two or more of the MIPS performance categories, then CMS will score and clinicians and/or groups will receive a payment adjustment based on the submitted data for the 2019 performance year.

For further information on Hospital and Post-Acute Care (PAC) programs, CLICK HERE for the recent Press Release about the CMS Quality Payment Program.

For further information on the Reporting Relief, refer to the CMS QPP COVID-19 Response Fact Sheet.

HERE is a Fact Sheet with this CMS QPP information for your reference.

Contact us at Kentucky REC with your questions. We’re here to help and are available at 859-323-3090.