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The Centers for Medicare and Medicaid Services is allowing more time for doctors participating in the Merit-Based Incentive Payment System to utilize an excessive and uncontrollable circumstance (EUC) waiver order that limits the negative impact of high-quality information to their funds.
Physician and digital teams, as well as others, have until March 31 to apply for a MIPS EUC waiver, and if the waiver is granted they then have the option to have their information reweighed to account for the impacts of the COVID-19 pandemic. If doctor teams do not submit information, they won’t incur a penalty.
Applicants need an HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application.
Groups and virtual groups can’t submit an application to override data that has already been submitted, according to CMS. Any data submitted for a group or virtual group, either before or after an application has been approved, will be scored. If only one performance category can be scored – meaning the other three performance categories are weighted at 0% – the group or virtual group will receive a final score equal to the performance threshold.
The MIPS eligible clinicians in the group will receive a neutral payment adjustment unless they have a higher score from individual or APM Entity participation. MIPS eligible clinicians participating as a virtual group always receive the virtual group’s score.
WHAT’S THE IMPACT? REACTION
The move drew positive reaction from the American Medical Association, which agreed that physicians and administrative staff needed flexibility this year when filing a MIPS EUC hardship application due to the Omicron surge.
“The increase in COVID cases – and increased demands – coincided with the original E&C hardship application deadline at the end of 2021,” said AMA Board of Trustees Immediate Past Chair Dr. Gerald Harmon. “As a result, physicians might have missed the opportunity to file for a hardship application and faced a payment adjustment. The re-opening of the 2021 application period will give physicians, including APM participants, much-needed relief and better ensure they avoid a negative 2023 MIPS payment adjustment.”
He added that if a physician, practice or physician/practice part of an APM is unsure of their status, they should submit an application to avoid a penalty. Physicians who do not submit any MIPS data for the 2021 MIPS program will automatically avoid a 2023 penalty.
THE LARGER TREND
In 2020, CMS implemented extreme and uncontrollable circumstances policy exceptions and extensions for measure-reporting and data-submission deadlines for programs such as MIPS, Medicare Shared Savings Program Accountable Care Organizations, the Hospital Inpatient and Outpatient Quality Reporting Programs, Hospital Readmissions Reduction Program, Hospital Value-Based Purchasing Program, and Skilled Nursing Facility Quality Reporting Program.
CMS officials said at the time that it “recognizes that quality measure data collection and reporting for services furnished during this time period may not be reflective of their true level of performance on measures such as cost, readmissions and patient experience during this time of emergency and seeks to hold organizations harmless for not submitting data during this period.”