The Centers for Medicare & Medicaid Services (CMS) would like to remind clinicians of important upcoming Merit-based Incentive Payment System (MIPS) dates and deadlines:
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December 31 – 2020 Promoting Interoperability Hardship Exception Application period closes. Clinicians, groups, and virtual groups who believe they are eligible for this exception may apply, and if approved, will qualify for a re-weighting of the MIPS Promoting Interoperability performance category. The 2020 Extreme and Uncontrollable Circumstances Application period also closes for all reasons not related to COVID-19. CMS will notify applicants via email whether their requests are approved or denied. If approved, the exception will also be added to the QPP Participation Status Tool (note: may not appear in the tool until the submission window opens in 2021).
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December 31 – 2021 virtual group election period closes. Solo practitioners and groups with 10 or fewer clinicians (including at least one MIPS eligible clinician) who want to participate in MIPS as a virtual group for the 2021 performance year must submit their election to CMS.
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January 4, 2021 – 2020 MIPS performance year data submission window opens.
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February 1, 2021 – 2020 Extreme and Uncontrollable Circumstances Application period closes for COVID-19 only. Clinicians, groups, and virtual groups who believe they are eligible for this exception may apply, and if approved, will qualify for a re-weighting of one or more MIPS performance categories. CMS will notify applicants via email whether their requests are approved or denied. If approved, the exception will be added to the QPP Participation Status Tool.
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New: CMS has finalized that for the 2020 performance year, Alternative Payment Model (APM) Entities may submit Extreme and Uncontrollable Circumstances applications as a result of COVID-19. For more information about the impact of COVID-19 on Quality Payment Program participation, see the Quality Payment Program COVID-19 Response webpage.
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March 1, 2021 – Deadline for CMS to receive 2020 claims for the Quality performance category. Claims must be received by CMS within 60 days of the end of the performance period. Deadline dates vary to submit claims to the MACs. Check with the MACs for more specific instructions.
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March 31, 2021 – 2020 MIPS performance year data submission window closes.
For More Information
To learn more, visit the QPP website and access the following resources:
Questions?
Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov
To receive assistance more quickly, please consider calling during non-peak hours—before 10 a.m. and after 2 p.m. Eastern Time.
- Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.
Reminder: Virtual Group Election Period for the MIPS 2021 Performance Year Closes on December 31
To form a virtual group for the 2021 Merit-based Incentive Payment System (MIPS) performance year, an election must be submitted to CMS via e-mail by December 31, 2020 (11:59 p.m. Eastern Time).
NOTE: A virtual group must submit an election to CMS for each performance year that it intends to participate in MIPS as a virtual group (as required by statute). If your virtual group was approved for the 2020 MIPS performance year and intends to participate in MIPS as a virtual group for the 2021 MIPS performance year, your virtual group is still required to submit an election to CMS for the 2021 MIPS performance year between October 1, 2020 and December 31, 2020 (11:59 p.m. Eastern Time).
What Is a Virtual Group?
A virtual group is a combination of 2 or more Taxpayer Identification Numbers (TINs) consisting of the following:
- Solo practitioners who are MIPS eligible (a solo practitioner is defined as the only clinician in a practice); and/or
- Groups that have 10 or fewer clinicians (at least one clinician within the group must be MIPS eligible). A group is considered to be an entire single TIN.
A virtual group has the flexibility to determine its own makeup. A solo practitioner or group can only participate in one virtual group during the performance year.
What Are the Advantages of Participating in a Virtual Group?
Participating in MIPS as a virtual group has the following advantages:
- Can increase performance volume in order to be reliably measured; and
- Provides an opportunity for members of a virtual group to collaborate, share resources, and potentially increase performance under MIPS.
What Is the Virtual Group Election Process?
The following highlights key items that a virtual group needs to complete prior to the submission of an election:
- Establish a formal written agreement between each TIN within the virtual group (see Agreement Sample Template in the Virtual Group Election Process Guide within the 2021 Virtual Group Toolkit).
- Identify an official virtual group representative.
The following outlines the elements that need to be included in an election:
- Acknowledgement that a formal written agreement has been established between each TIN within the virtual group.
- The name and contact information for the official virtual group representative.
- The name and TIN for each practice, and all associated National Provider Identifiers (NPIs) under each TIN.
Once complete, the virtual group must submit the election via e-mail to CMS at MIPS_VirtualGroups@cms.hhs.gov by 11:59 p.m. Eastern Time on December 31, 2020 (see Election E-mail Sample in the Virtual Group Election Process Guide within the 2021 Virtual Group Toolkit).
For further information regarding virtual group participation in MIPS, virtual group reporting requirements, the election process, checklists for virtual groups to consider, and sample templates, download the 2021 Virtual Group Toolkit.
Need Help?
- Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10 a.m. and after 2 p.m. Eastern Time.
- Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.
- Connect with your local technical assistance organization. We provide no-cost technical assistance to small, underserved, and rural practices to help you successfully participate in the Quality Payment Program.
Extreme and Uncontrollable Circumstances Application
To further support clinicians during the COVID-19 public health emergency, CMS has 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 our 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 will remain December 31, 2020. Remember, if you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply.
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, but may not appear in the tool until the submission window is open in 2021.
For APM Entities Only
In the 2021 Medicare Physician Fee Schedule (PFS) Final Rule, the Centers for Medicare & Medicaid Services (CMS) has 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 has extended the application deadline 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 (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: QPP@cms.hhs.gov. 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.
CMS and its contractor, Acumen, LLC, are gathering input on episode groups to consider for Wave 4 of the Merit-based Incentive Payment System (MIPS) cost measure development through a Call for Public Comment. Stakeholders are invited to submit their feedback in response to the information and questions included in the document between now and February 5, 2021, at 11:59 p.m. Eastern Time.
The rest of this email contains more details about the public comment posting and participation. Please feel free to share this message with anyone who may be interested in providing input on the public comment posting.
Why use a public comment approach?
CMS and Acumen are using a public comment approach to solicit input on which measures to prioritize for Wave 4 development instead of the traditional Clinical Subcommittee (CS) approach. We understand that 2020 has presented new challenges and clinicians and specialty societies have expressed concern about their limited bandwidth during this time. The public comment approach allows for broader and more flexible stakeholder participation.
Where can stakeholders access the public comment materials and provide feedback?
Stakeholders may access the public comment materials on CMS's Currently Accepting Comments Page. The following documents are available for stakeholders to download and review:
To submit feedback, stakeholders may either: (i) email a comment letter to macra-episode-based-cost-measures-info@acumenllc.com, or (ii) submit a response to the Wave 4 Measure Development Survey: https://www.surveymonkey.com/r/wave_4_development.
How will the public comment process work?
CMS and Acumen are soliciting input similar to what has been gathered in the past via the CS. Stakeholders may respond to targeted questions about the clinical areas and candidate episode groups. Stakeholders may also provide input on:
- Important considerations for measure development in Wave 4
- Preliminary measure specifications for the Wave 4 candidate episode groups
- Clinical areas and concepts to explore for future Waves of development
Which clinical areas are under consideration in the public comment posting?
The 4 clinical areas under consideration for development in Wave 4 are:
- Heart Failure
- Mental and Behavioral Health
- Therapy and Rehabilitation
- Rheumatology/Arthritis
We are also seeking input on clinical areas and measure concepts and considerations for future Waves of development:
- Anesthesiology
- Emergency Medicine
- Oncology Coding
- Otolaryngology
- Pathology
- Radiology
Where can stakeholders learn more about the public comment period?
As part of our outreach efforts, we plan to share a pre-recorded presentation in January 2021 so stakeholders can learn more about the public comment process. Stakeholders may also review the public comment posting materials on CMS's Currently Accepting Comments Page.
Should you have any further questions, please contact the Acumen MACRA Cost Measures Support Team via email at macra-episode-based-cost-measures-info@acumenllc.com.
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