June 2021 MACRA Minute Newsletter

Applications for the 2021 MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exceptions are Now Open.

Applications are now open for the MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exception for the 2021 Performance Year. Those interested must submit their applications to CMS by December 31, 2021.

Who is Eligible for a Promoting Interoperability Hardship Exception?

MIPS eligible clinicians, groups, and virtual groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception Application whether they’re reporting traditional MIPS or the APM Performance Pathway. Exceptions are granted if they:

  • Are a small practice;
  • Have decertified EHR technology;
  • Have sufficient Internet connectivity;
  • Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues; or
  • Lack control over the availability of CEHRT.

NOTE: If you’re already exempt from submitting Promoting Interoperability data, you don’t need to apply.

Who is Eligible for an Extreme and Uncontrollable Circumstances Exception?

MIPS eligible clinicians, groups, and virtual groups may submit an application to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must:

  • Cause you to be unable to collect information necessary to submit for a MIPS performance category;
  • Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for 3 months), and/or;
  • Impact your normal process, affecting your performance on cost measures and other administrative claims measures.

NOTE: For the 2021 Performance Year CMS will continue to use the Extreme and Uncontrollable Circumstances policy to allow clinicians, groups, virtual groups, and APM Entities to submit an application requesting reweighting of performance categories due to the current COVID-19 public health emergency.

How Do I Apply?

In order to apply, you must create a HCQIS Access Roles and Profile (HARP) account to submit an Extreme and Uncontrollable Circumstances Application. For more information on how to obtain a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you sign into QPP with your HARP credentials, click ‘Exceptions Application’ on the left-hand navigation and then select ‘Extreme and Uncontrollable Circumstances’ or ‘Promoting Interoperability Hardship.’

How Do I Know if I’m Approved?

If you submit an application for either exception, you’ll be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool.

For More Information

Visit the MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exception QPP webpages for more information and link to the application.

Download the 2021 MIPS Promoting Interoperability Hardship Exception Application Guide and the 2021 Extreme and Uncontrollable Circumstances Exception Application Guide now available on the QPP Resource Library.

CMS Reweighting 2020 MIPS Cost Performance Category

CMS recognizes the impact of the COVID-19 pandemic public health emergency on clinicians across the country and continue to offer flexibilities to provide relief where possible. CMS would like to inform all MIPS eligible clinicians that they are reweighting the cost performance category from 15% to 0% for the 2020 performance period. The 15% cost performance category weight will be redistributed to other performance categories in accordance with § 414.1380(c)(2)(ii)(D). Please see the table below for reweighting scenarios.

CMS’s analysis of the underlying data for the 2020 performance year, in comparison to prior years’ data, shows that the volume of data available to calculate the scores for the cost measures has significantly decreased overall. As a result, they do not believe they can reliably calculate scores for the cost measures that would adequately capture and reflect the performance of MIPS eligible clinicians. Given these circumstances, in accordance with § 414.1380(c)(2)(i)(A)(2), CMS will assign a weight of 0% to the cost performance category for the 2020 performance period and redistribute the prescribed weight of 15% to another performance category or categories.

Specifically, CMS does not believe they can reliably calculate scores for the cost measures based on the following reasons, as shown by analysis of the cost performance category data for the 2020 performance year:

  • A significant decrease in service utilization in 2020 demonstrates cost measures may not accurately characterize patient risk due to the lack of diagnosis information in the lookback periods used for risk adjustment.
  • Episodes with COVID-19 diagnoses generally have higher observed and risk-adjusted costs, indicating COVID-19 impacted service utilization and wasn’t sufficiently accounted for through risk adjustment.
  • The overall number of clinicians who met 2020 cost measure case minimums substantially decreased from prior performance years. A substantial portion of clinicians had episodes with COVID-19.

Clinicians don’t need to take any action as a result of this decision because the cost performance category relies on administrative claims data.

MIPS Performance Category Weight Redistribution Policies Finalized for the 2020 Performance Period

The table below illustrates the 2020 performance category weights and reweighting policies that CMS will apply to clinicians under MIPS.  As a reminder, under § 414.1380(c), if a MIPS eligible clinician is scored on fewer than 2 performance categories (meaning 1 performance category is weighted at 100% or all performance categories are weighted at 0%), they will receive a final score equal to the performance threshold and a neutral MIPS payment adjustment for the 2022 MIPS payment year.

MIPS Performance Category Reweighting ScenarioQuality Category WeightCost Category WeightImprovement Activities Category WeightPromoting Interoperability Category Weight
No Additional Reweighting Applies55%0%15%30%
Reweight 2 Performance Categories
No Promoting Interoperability, No Cost85%0%15%0%
No Quality, No Cost0%0%15%85%
No Improvement Activities, No Cost70%0%0%30%

June Telligen QPP Connect Live Call

As part of the Performers of Excellence Award program, we are hosting a call-in series called Telligen QPP Connect Live! Each month we highlight a topic with a few slides to kick off the call/start the conversation and then you can ask questions (on the topic or anything else you would like).  These calls will happen the 3rd Wednesday of every month from 12:00 – 1:00 Central. On June’s call we will review the Promoting Interoperability Hardship and Extreme and Uncontrollable Circumstances Applications process. As always, we will have time at the end of the presentation for any MIPS questions you have. Please join us on Wednesday June 16th at noon CST using the link below

Join Zoom Meeting: https://telligen.zoom.us/j/99104893418?pwd=MFRNZWdOV3ZwaEQ3VkQ3aDJidWJIZz09

Meeting ID: 991 0489 3418

Passcode: 784640

One tap mobile

+19294362866,,99104893418# US (New York)

+16699006833,,99104893418# US (San Jose)

Dial by your location

        +1 929 436 2866 US (New York)

        +1 669 900 6833 US (San Jose)

        877 853 5257 US Toll-free

        888 475 4499 US Toll-free

Meeting ID: 991 0489 3418

CMS Webinars

Reminder you can view previous CMS webinars on various MIPS categories in the Webinar Library on the QPP website.

Telligen Webinars

Our monthly webinar for May featured guest speaker Leah Nash from IMPAQ. Leah gave a detailed overview of the Cost Performance Category. You can view the recording or download the slides from our website.

New Resources in the QPP Resource Library

The following resources were updated or added in May

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