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Quality Payment Program’s Response to COVID-19

Thursday, February 04 2021

The COVID-19 public health emergency (PHE) has affected the provision of healthcare by clinicians throughout the United States in unprecedented ways. In response to the pandemic, the Centers for Medicare & Medicaid Services (CMS) has implemented many flexibilities for clinicians participating in the Quality Payment Program (QPP) and the Merit-based Incentive Payment System (MIPS). The flexibilities for the 2020 and 2021 performance years are summarized below.

Availability of Extreme and Uncontrollable Circumstances (EUC) Exception – Clinicians who have been impacted by the COVID-19 PHE may request reweighting of one or more MIPS performance categories for the 2020 performance year. CMS has extended the application deadline for the EUC exception to February 1, 2021, at 8pm ET.

  • Individual clinicians, groups, and virtual groups may apply for an EUC exception for any or all performance categories if the pandemic is preventing them from collecting data for an extended period of time or could negatively impact their Cost performance. If an application is approved, the applicable performance category will be reweighted to 0% and will not contribute to the final score unless the individual or group submits data for those categories.
  • APM entities may request reweighting of all performance categories if at least 75% of the MIPS-eligible clinicians qualify for reweighting in the Promoting Interoperability category. Data submission would not override performance category reweighting. If an application is approved, the APM entity would receive a final score equal to the performance threshold and a neutral payment adjustment.

Doubled Complex Patient Bonus – CMS is increasing the number of points available for the complex patient bonus in the 2020 performance year. The maximum number of points available to be added to the MIPS 2020 final score is being doubled from 5 to 10 points in recognition of the increase in patient complexity resulting from COVID-19.

New Improvement Activity: COVID-19 Clinical Data Reporting with or without Clinical Trial – CMS has added a new high-weighted improvement activity for the 2020 and 2021 performance years. Clinicians may receive credit for this activity if they have:

  • Participated in a COVID-19 clinical trial using a drug or biological product to treat patients with COVID-19, and report findings through a clinical data repository or clinical data registry for the duration of the study; OR
  • Participated in the care of COVID-19 patients and submitted relevant clinical data to a clinical data registry for ongoing or future COVID-19 research.

For clinicians who participate in both the COVID-19 Clinical Data Reporting with or without Clinical Trial activity and the existing Participation in a 60-day or greater effort to support domestic or international humanitarian needs activity, CMS will give full credit for the MIPS Improvement Activities performance category.

Inclusion of Telehealth Services in the Cost Performance Category for the 2021 Performance Year – CMS has updated existing measure specifications in the Cost performance category to include telehealth services where these services are applicable to existing episode-based cost measures and the Total Per Capita Cost measure.

Please visit the Quality Payment Program COVID-19 Response webpage for additional information on the flexibilities that CMS has implemented in all performance years, as well as the 2021 Quality Payment Program Final Rule Resources for additional information on the 2021 QPP final rule.


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