Volume 3 Ed. 4 | April 23, 2020
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MIPS Extreme and Uncontrollable Circumstances Policy in Response to COVID-19 Application Re-Opened
The Centers for Medicare & Medicaid Services (CMS) is flexibly providing relief to clinicians responding to the 2019-Novel Coronavirus Disease
(COVID-19) pandemic.
If you are a Merit-based Incentive Payment System (MIPS)-eligible clinician and do not submit any MIPS data by
April 30, 2020, 8 p.m. ET,
you will not need to take any additional action to qualify for the automatic extreme and uncontrollable circumstances policy. You will be automatically identified and will receive a neutral payment adjustment for the 2021 MIPS-payment year.
Please note, CMS has updated the
Quality Payment Program (QPP) Participation Status Tool
so eligible clinicians can see if the policy has been automatically applied.
Additional 2019 Relief Measure
Who should submit an application?
- Individual clinicians who started, but are unable to complete, their data submission;
- Groups that started, but are unable to complete, their data submission; and
- Virtual groups that are unable to start or complete their data submission.
For More Information:
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7 Days Left Until MIPS Data Submission!
The data submission period for MIPS-eligible clinicians who participated in the 2019 performance period of the QPP can be submitted and updated until
8 p.m. EDT on April 30, 2020.
To learn more about how to submit data, please review the resources available in the
QPP Resource Library
.
The data submission period through the CMS Web Interface for Accountable Care Organizations (ACOs), pre-registered groups, and virtual groups also opened on January 2, 2020, and closes on April 30, 2020. Quality measures reported via Medicare Part B claims have been submitted throughout the 2019 performance period. Sign in to
qpp.cms.gov
for your preliminary feedback on Part B claims measure data processed to date.
For More Information
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MIPS Data Submission Portal Pointers
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Submission Tip #1
The Promoting Interoperability (PI) re-weighting for special statuses and approved applications have been updated on the QPP Portal! CMS has updated the PI section of the QPP Portal to indicate if an approved PI hardship exception application or special status automatic re-weighting has been applied to the individual or the group. Watch for a warning box pop up if a submitter attempts to explore the PI page in the QPP Portal. Selecting continue or entering in any data, will
override your re-weighting and or hardship exception, and you
will be scored in the PI performance category.
Submission Tip #2
Click the “Print” button at the top of your Reporting Overview,
as there is no "save" or "submit" button once you have entered your MIPS data. Data entered in the submission portal at the close of the submission window on April 30, 2020, at 8 p.m. ET is what CMS will use to calculate your score. Be sure to safeguard your tax identification numbers (TINs) in your prints.
Submission Tip #3
Submit early; do not wait!
CMS has indicated that the call volume may be higher than normal. If you are locked out of your Health Care Quality Information Systems (HCQIS) Access Roles and Profile (HARP) account and need technical assistance, you may want to call during the hours of 8–10:00 a.m. EDT
or
2–8:00 p.m. EDT, which are off-peak hours indicated by the CMS QPP Service Center. If you have already submitted your data, log back in to check for any score adjustments that may have been made based on previously unprocessed claims or any third-party vendors that may have submitted data on your behalf.
Submission Tip #4
If you are part of an Alternative Payment Model (APM), such as an ACO, please confirm with your ACO that they have uploaded the Quality MIPS data on your behalf.
Do not forget you are required to submit your own data in the PI category unless otherwise specified by your ACO.
Do you need assistance with MIPS-data submission?
Do not wait! Contact HSAG’s QPP Service Center today. We can help.
Phone: 1.844.472.4227 (8 a.m.–8 p.m. ET)
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Have you established a HARP account and identified roles needed for submission? Check out some HARP Frequently Asked Questions at the
CMS HARP Help website
. If you have a HARP account, the following are some tips to keep your account active and how to create a strong password.
Passwords must:
- Be changed every 60 days.
- Be changed prior to expiration.
- Are changed by going to portal.cms.gov > My Profile>Click on Change My Profile>Change Password.
- Contain between eight and twenty characters.
- Contain at least one upper case letter, lower case letter, and number.
- Not contain a dictionary word of five letters or more.
- Not contain more than four sequential numbers, such as 1234.
- Contain a special character.
- Not contain these special characters: ? < > ( ) ' " ? | &.
Here are some examples of acceptable passwords:
- Hbfc#867 or H@ll0ween (CAP Initials of first and last name-@-lower case business initials and 3 numbers)
- JA@hc876 (Josh Allen who works at Health Clinic)
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QPP Frequently Asked Question of the Month
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Question: Are clinicians able to go back and delete 2019 MIPS data in order to benefit from the Extreme and Uncontrollable Circumstance policy?
Answer:
No. CMS has reopened the 2019 Extreme and Uncontrollable Circumstance policy application at the
CMS Quality Support page
. Below is some guidance in completing your application.
- Select individual, group, or virtual group as appropriate to your level of participation;
- Select 1/1/2020 and 4/30/2020 as your start and end dates;
- Indicate that you are unable to complete data submission due to the COVID-19 pandemic;
- Select all 4 performance categories for reweighting.
Question:
If practices that have claims automatically coming through on the portal, but did not submit any other category and received below the 30-point threshold, will they receive a penalty in 2021 for this?
Answer:
Yes. If your practice did not intend to participate as a group and has a quality score based on individual claims reporting, the practice should submit an
application
on behalf of the group, selecting all 4 performance categories for reweighting.
Question: What happens if I am a MIPS-eligible clinician covered by the automatic extreme and uncontrollable policy, but still submit 2019 data?
Answer:
That depends on how many performance categories you submit data for. See the quick reference table below.
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Question: Which eligible clinicians (ECs) are still projected to receive a 2021 payment penalty?
Answer:
An individual EC or group with a score between 1 and 29.99 points will receive a negative adjustment. To receive a score other than the performance threshold (30 points), an individual would have to submit data in 2 or 3 categories. Groups will be scored on all categories if they submit data in 1 category―the automatic policy (and reweighting unless data is submitted) only applies to individual reporting.
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New COVID-19 Improvement Activity
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CMS COVID-19 Stakeholder Call Recordings Available
CMS has been hosting regular calls with a variety of clinicians, hospitals, other facilities, and states in an effort to keep stakeholders updated on their COVID-19 efforts. CMS understands that not everyone is available to attend the calls live, and is sharing access to the call recordings along with transcripts on the following link:
https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts
. CMS will continue to host calls and share information through their list serves and media.
To keep up with the important work of the White House Coronavirus Task Force in response to COVID-19, visit
https:/www.coronavirus.gov
. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the
Current Emergencies Website
.
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COVID-19 Resources and Preparedness
In light of the COVID-19 pandemic, HSAG understands the priority to keep your patients and staff safe.
COVID-19 Resources:
CDC = Centers for Disease Control and Prevention
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To help you prepare for the 2020 performance year of the MIPS, CMS has posted new/updated resources to the
QPP Resource Library.
QPP Resources:
* CAHPS® = Consumer Assessment of Healthcare Providers and Systems®
CAHPS® is a registered trademark of the Agency for Healthcare Research and Quality (AHRQ).
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Subscribe to Get the Information You Need
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Subscribe to HSAG's QPP Quest Digest
Invite your practice staff, practices you refer patients to, and other colleagues to subscribe to HSAG’s QPP Quest Digest!
Stay informed of all monthly QPP updates, deadlines, no-cost webinars and best practices by subscribing
here
.
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CMS QPP Listserv
Don't forget to sign up on the
CMS.gov QPP website
. Once you've accessed the QPP page, scroll to
[Subscribe to Updates]
at the bottom of the page and insert your email address before clicking
[Subscribe]
. The QPP listserv is a valuable resource to stay informed of webinars and important QPP deadlines.
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