MIPS: You’re Excused (Hopefully)

Due to the ongoing COVID-19 pandemic, the Centers for Medicare & Medicaid Services (CMS) will allow physicians to apply for complete or partial exemptions from the 2020 Merit-based Incentive Payment System (MIPS) program.

The Medicare Access and CHIP Reauthorization Act (MACRA) was designed to shift physician payment so that it rewards value and quality over volume via the creation of the Quality Payment Program (QPP). The QPP offers two pathways for reimbursement: MIPS and Advanced Alternative Payment Models (APM). Most dermatologists who participate in the QPP take the MIPS route, and the clock for 2020 MIPS exemptions is ticking. To be exempt from 2020 MIPS reporting, you must act before December 31, 2020. Don’t wait until the last minute. Get approved now so you won’t have to worry about MIPS again until January 2021.

What to Do

To get approved, complete the Extreme and Uncontrollable Hardship Exemption Application and indicate on the application that it is due to the COVID-19 Public Health Emergency. If they are approved, dermatologists can have any or all of the MIPS performance categories re-weighted to zero due to pandemic-related extreme and uncontrollable circumstances. This means that the category will receive zero weight when CMS calculates your final score.

Such events may include:

• Inability to collect the information needed to submit for a MIPS performance category
• Inability to submit information to score a MIPS performance category for an extended period of time
• Interruption in normal processes, affecting your performance on cost measures and other administrative claims measures.

You must include a justification for how your practice has been significantly impacted by COVID-19.

There’s another exemption, too. You can also apply for the Promoting Interoperability hardship exception application if you are a small practice, have decertified electronic health record technology, have insufficient internet connectivity, faced extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues, and lack control over certified electronic health record technology (CEHR) availability.

Why Exemptions Matter

If you don’t get the minimum amount of MIPS points, you will be hit with financial penalties. Higher points are needed to earn bonuses.

These exemptions will help you avoid any penalties, but you likely will not be able to receive any incentive payments for the year, either, as this is a budget-neutral program. If there is no penalty revenue, there is no money for incentive bonuses.

The exception is for those scoring 85 MIPS points or higher, because there is a $500 million bucket of bonus money for exceptional performance.

To find out if you are approved, check the status of your application by signing into QPP.