This week, CMS announced that physicians will have the option to opt out completely or partially from the 2020 Merit-based Incentive Payment System (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. However, submitting any MIPS data to CMS will override the hardship exception application, and physicians will be scored on their submission.
The flexibilities should assist with allowing practices to focus their attention on caring for patients during the pandemic and reduce administrative burden. ISASS will continue to monitor the impact COVID-19 is having on practices and advocate to CMS for the appropriate relief and to ensure CMS liberally grants hardship requests due to the COVID-19 PHE.
In addition, the CMS Quality Payment Program website (qpp.cms.gov) is in the process of being updated with the 2020 policy and should reflect the announcement along with additional educational materials in a couple of 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 rulemaking.