COVID-19 & MIPS Reporting Year 2020

Despite the on-going health crisis, the Quality Payment Program is still in full swing for Reporting Year 2020. MIPS practices, ACOs, and APMs are all expected to report their 2020 performance in Q1 2021. So far, CMS has only made some minor alterations to the QPP/MIPS program, largely focused on some “housekeeping-type” changes that will give QCDRs a little more breathing room. That said, CMS has indicated there will be changes coming to the MIPS program, but they have not given a clear timeline or any idea on what will change.

What Has Changed?

• The biggest change has already come and gone, the data submission deadline for RY 2019 was moved to April 30. Those who did not submit data by that deadline were given a neutral adjustment instead of a penalty as the pandemic trigged an “Extreme and Uncontrollable Circumstances (E&UC) policy” exemption. Practices and providers that did submit will receive their adjustment accordingly.
• New Improvement Activities (high-weight) for RY2020 were created that promotes participation in COVID-19 treatment clinical trials and reporting on COVID-19 data to a registry or data repository.
• Extended the deadline for the QCDR measure & collection policies from Jan 1, 2021 to Jan 1, 2022. (This will require QCDRs to follow new rules for gathering more measures and sharing “unique” measures with others)
• Extended the Call for Quality Measures & the submission of DVER to June 30

What Will Change?

At this point in time, it would be pure speculation as to what will change. The largest lobby groups have advocated for a 90-day reporting window for all four categories, another automatic trigger of the E&UC policy, a nation-wide “pause” on QPP, and other substantive changes. We won’t know until sometime this summer or even this fall if there will be any changes to this reporting year.

Therefore, it is our recommendation to proceed with your RY2020 plans and do not plan on making any modifications to your QPP behavior. Expect that while CMS will make changes, if you continue on the “there’s no change” path you will likely exceed their modified rules whenever they are released.

When CMS does release their changes, we will be here to post an update and provide education to help you understand and best navigate the rules.