Last Updated 05/16/2023
The Centers for Medicare & Medicaid Services (CMS) is implementing multiple flexibilities for the Quality Payment Program (QPP) in response to COVID-19.
Performance Year
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2021 Performance Year
Due to the continuing COVID-19 PHE we've applied our Merit-based Incentive Payment System (MIPS) automatic extreme and uncontrollable circumstances (EUC) policy to all individual MIPS eligible clinicians. We’ve also reopened our EUC exception application for groups, virtual groups and Alternative Payment Model (APM) Entities.
Please review our QPP COVID-19 Response Fact Sheet for additional information.
MIPS Automatic Extreme and Uncontrollable Circumstances Policy
We've applied the MIPS automatic EUC policy to all individual MIPS eligible clinicians for the 2021 performance year. This policy doesn’t apply to clinicians participating in MIPS as a group, virtual group or APM Entity.
MIPS eligible clinicians reporting as individuals will only be scored on performance categories for which data are submitted or available for scoring (such as the automatic credit awarded to participants in APMs for the improvement activities performance category.) All other performance categories will be reweighted to 0% of their final score. Under the automatic EUC policy, the cost performance category is always weighted at 0%, even if data are submitted for other performance categories.
- MIPS eligible clinicians who don't submit 2021 MIPS data by the March 31, 2022 deadline will have all performance categories reweighted to 0% and automatically receive a neutral payment adjustment, unless they have a higher score from group or APM Entity participation.
- MIPS eligible clinicians reporting as individuals who submit 2021 MIPS data for 1 performance category by the March 31, 2022 deadline will automatically receive a neutral payment adjustment, unless they have a higher score from group or APM Entity participation.
- Note that participants in APMs are eligible to receive automatic credit in the improvement activities performance category; for these MIPS eligible clinicians, submitting data for the quality and/or Promoting Interoperability performance categories will initiate a score in the improvement activities performance category.
- Note that participants in APMs are eligible to receive automatic credit in the improvement activities performance category; for these MIPS eligible clinicians, submitting data for the quality and/or Promoting Interoperability performance categories will initiate a score in the improvement activities performance category.
- MIPS eligible clinicians reporting as individuals who are scored on 2 or 3 MIPS performance categories by the March 31, 2022 deadline will receive a final score based on the performance categories for which data is submitted and may earn a negative, neutral or positive payment adjustment. (These MIPS eligible clinicians will receive the highest final score that can be attributed to them from individual, group or APM Entity participation.)
MIPS Extreme and Uncontrollable Circumstances Application Reopens and Deadline Extended to March 31, 2022
We’ve reopened the 2021 MIPS EUC application to allow groups, virtual groups and APM Entities to submit an application requesting MIPS performance category reweighting due to the ongoing COVID-19 PHE. (Because of the automatic EUC policy, individual clinicians don’t need to submit an application.)
MIPS EUC applications citing COVID-19 as the triggering event can be submitted until Thursday, March 31, 2022 at 8 p.m. ET. Apply Now. You need a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application. For more information on HARP accounts, refer to the Register for a HARP Account document in the QPP Access User Guide.
Groups and Virtual Groups
Groups and virtual groups can’t submit an application to override data that has already been submitted.
Any data submitted for a group or virtual group (before or after an application has been approved) will be scored.
- If only 1 performance category can be scored (meaning the other 3 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.
Example: A small practice reported Medicare Part B claims measures throughout the performance year and automatically received a group-level quality score based on these measures. The practice submits a group-level EUC application citing COVID-19 and the group is approved for reweighting all performance categories.
- As long as no additional data is submitted at the group level (or available for scoring, such as the automatic improvement activities credit awarded to groups with clinicians participating in an APM), the improvement activities, Promoting Interoperability and cost performance categories will be weighted at 0%.
- We’ll still score the group on their reported Medicare Part B claims measures, but the quality performance category will be weighted at 100% of the group’s MIPS final score.
- As a result, the group will receive a final score equal to the performance threshold and all MIPS eligible clinicians in the group will receive a neutral payment adjustment unless they have a higher score from individual or APM Entity participation.
For more information on this application, please refer to the 2021 MIPS Extreme and Uncontrollable Circumstances Application Guide (PDF).
APM Entities
Official representatives of APM Entities participating in MIPS, including Shared Savings Program Accountable Care Organizations (ACOs), can submit a MIPS EUC application on behalf of all MIPS eligible clinicians in the APM Entity for the 2021 performance year. If approved, all of the MIPS eligible clinicians in the APM Entity will receive a neutral MIPS payment adjustment in the 2023 MIPS payment year.
There are some differences from our existing policy for individuals, groups, and virtual groups.
- APM Entities are required to request reweighting for all performance categories (they wouldn’t be able to select some, but not all, performance categories).
- At least 75% of the MIPS eligible clinicians in the Entity need to qualify for reweighting in the Promoting Interoperability performance category.
- Data submission by an APM Entity doesn’t override performance category reweighting. (APM Entities with an approved application will receive a final score equal to the performance threshold and the MIPS eligible clinicians in the APM Entity will receive a neutral payment adjustment even if data are submitted.)
For more information on this application, please refer to the 2021 MIPS Extreme and Uncontrollable Circumstances Application Guide (PDF).
Shared Savings Program
Official representatives of Shared Savings Program ACOs can submit a MIPS EUC application on behalf of all MIPS eligible clinicians in the ACO for the 2021 performance year; if approved, all of the MIPS eligible clinicians in the ACO will receive a neutral MIPS payment adjustment in the 2023 MIPS payment year. (The application must be submitted by an ACO executive/official, not by an ACO participant or clinician participating in the ACO.) Refer to the APM Entities section above for more information.
The Shared Savings Program Quality EUC policy for determining shared savings and losses applies to all Shared Savings Program ACOs for performance year 2021. CMS considers all ACOs to be affected by the COVID-19 PHE and the Shared Savings Program EUC policy applies for performance year 2021. ACOs that are able to report quality data via the APM Performance Pathway (APP) and meet MIPS data completeness and case minimum requirements will receive the higher of their ACO quality score or the 30th percentile MIPS quality performance category score. ACOs that are unable to report quality data via the APP and meet the MIPS quality data completeness and case minimum requirements, will have their quality score set equal to the 30th percentile MIPS quality performance category score.
Complex Patient Bonus Doubled
As finalized in the CY 2022 Physician Fee Schedule Final Rule, you can earn up to 10 bonus points for the Complex Patient Bonus for the 2021 performance year (to be added to your 2021 MIPS Final Score).
QCDR Approval Criteria: Measure Testing and Data Collection Delay
The Qualified Clinical Data Registry (QCDR) measure approval criteria necessitates QCDRs collecting data from clinicians in order to assess the measure before including it in the QCDR’s self-nomination application. We anticipate that QCDRs may be unable to collect, and clinicians unable to submit, data on QCDR measures due to prioritizing the care of COVID-19 patients. Therefore, we are delaying implementation of the QCDR measure testing and data collection policies by 1 year, from the 2021 performance period to the 2022 performance period.
COVID-19 Improvement Activity
Due to the anticipated need for continued COVID-19 clinical trials and data collection, MIPS eligible clinicians and groups who meet the activity criteria will be able to receive credit for the COVID-19 Clinical Data Reporting with or without Clinical Trial improvement activity through the MIPS 2021 performance period.
Where Can I Learn More?
- CMS’s Current Emergencies
- Medicare IFC: Revisions in Response to the COVID-19 Public Health Emergency (CMS-1744-IFC)
- Medicare and Medicaid IFC: Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (CMS-5531 IFC)
- Medicare and Medicaid IFC: Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (CMS-3401-IFC)
- CY 2021 Physician Fee Schedule Final Rule
- CY 2022 Physician Fee Schedule Final Rule
You can subscribe to the QPP listserv and you can also contact the Quality Payment Program at 1-866-288-8292, Monday through Friday, 8:00 a.m. - 8:00 p.m. Eastern Time or by email at: QPP@cms.hhs.gov. Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.