This week, CMS announced that physicians will have the option to opt-out completely or partially from the 2020 QPP’s MIPS program by completing a hardship exemption application and indicating it is due to the COVID-19 Public Health Emergency (PHE). Individual clinicians and group practices have until December 31, 2020 to complete the hardship application.
CMS plans on providing physicians with a couple of options on the hardship exemption application. For example, a practice may submit a hardship application and indicate that they do not want to be scored on Cost and Quality and have their score calculated based on just Promoting Interoperability and Improvement Activities. Alternatively, practices may submit a hardship application and opt-out of all four performance categories and be held harmless from a 2022 payment adjustment.
Submitting any MIPS data to CMS will override the hardship exception application and physicians will be scored on their submission.
The CMS QPP.CMS.GOV website is in the process of being updated with the 2020 policy and should reflect the announcement along with additional educational materials within the next two weeks. The information currently posted on the website is regarding the 2019 MIPS COVID-19 policy. CMS has also indicated that additional information on MIPS COVID-19 policy will be included in upcoming rule-making.
These changes of policy by CMS were made in response to an AMA coalition letter of nearly 20 health care provider organizations that represent doctors, nurses, hospitals, dentists and more, calling on congressional leaders to fix a taxation penalty embedded in the CARES Act. Without congressional action, many providers will lose more than a fifth of the grant funds approved by Congress to sustain lifesaving care during the COVID-19 pandemic. The groups are asking lawmakers to correct unintentional tax consequences of policies meant to provide vital funding to health care providers through the Public Health and Social Services Emergency Fund (also referred to as the Provider Relief Fund) and other programs as part of the nation’s response to the COVID-19 pandemic.
The following is the full fact sheet published by CMS on this topic. The fact sheet may also be downloaded.