MIPS Reporting Year 2020 Guidance Update

After weeks of waiting, CMS has finally updated its MIPS guidance around the Reporting Year 2020 (RY2020). While CMS may make additional changes, this is the first major change for RY2020 we have seen thus far. For 2020, physicians and groups reporting for MIPS may submit an Extreme & Uncontrollable Circumstances Application to have some or all the MIPS categories reweighted to 0%. You must justify how COVID-19 has harmed your ability to achieve the category (or categories) you are asking to have reweighted.

Unlike the last-minute automatic reweight of RY2019, this will require effort on your organization’s part. You must provide examples showing:

• How the pandemic prevented you from collecting necessary MIPS data for a category (or categories) (such as seeing patients only via telemedicine and no reliable method of collecting Quality Category data)
• How the pandemic will prevent you from scoring a category (such as missing 3 months’ worth of Quality Category data)
• How the pandemic impacted your normal business process that would affect your cost measures or other administrative claims measures (such as unable to send claims due to lack of enough billing staff)

SHP’s Recommendation

We recommend that if you intended to submit for RY2020 and you feel your data is complete enough to score well, continue to move forward with that plan. A reweight request of a category may result in a lower score than desired. A total reweight of MIPS will result in a score of 0, with penalty avoidance, but may harm your score on Physician Compare: https://www.medicare.gov/physiciancompare/

That said, if you do feel like a reweight will help your organization and you feel that you can justify the request to CMS, follow the instructions here: https://qpp.cms.gov/mips/exception-applications#extremeCircumstancesException-2020

As always, SHP is here to help you with your Quality Payment Program participation questions, and we will bring you timely information regarding any changes to the MIPS program for 2020 and beyond.