2020 QPP: CMS Extreme and Uncontrollable Circumstances Exception

In June, the Centers for Medicare and Medicaid Services (CMS) announced a new exception policy for clinicians, groups, and virtual groups participating in the Merit-based Incentive Payment System (MIPS) track of the Quality Payment Program (QPP). Under the new CMS guidance, MIPS-eligible clinicians can apply for an “Extreme and Uncontrollable Circumstances” exception to 2020 QPP reporting requirements. Here’s what you need to know about this new policy.

COVID-19 Has Changed How Clinicians Practice, Making QPP Reporting Difficult

The COVID-19 pandemic has altered clinical practice. Outpatient visits have declined substantially, reducing patient volume for MIPS reporting. Telemedicine visits have increased, but not enough to make up for the decline in in-person visits, leaving clinicians with far fewer patient interactions in the first half of 2020 than in prior reporting periods. Also, the lack of physical interaction in telemedicine visits may inhibit data collection and performance on quality groups. Finally, many groups, and the Medicare program itself, have relaxed or changed documentation requirements due to COVID-19.

These changes in patient volume, physical patient contact, and documentation may make it difficult for clinicians and groups to meet QPP reporting requirements and MIPS performance thresholds in 2020, despite their best efforts. 

A New CMS Policy Would Provide QPP Reporting Relief

In March, CMS recognized the difficulties facing clinicians and groups in completing 2019 QPP reporting and offered extended reporting deadlines and reporting exceptions. Now, CMS has also recognized the challenges facing MIPS-eligible clinicians and groups in meeting the 2020 QPP reporting requirements and MIPS performance thresholds.

In June, CMS expanded upon 2019 QPP regulatory relief to allow QPP reporting exceptions in 2020 as well. Clinicians, groups, and virtual groups may apply for an “Extreme and Uncontrollable Circumstances” exception to eliminate reporting requirements for any or all of the four MIPS performance categories in 2020, including Quality, Cost, Improvement Activities, and/or Promoting Interoperability.

An Overview of the Extreme and Uncontrollable Circumstances Exception Policy

The Extreme and Uncontrollable Circumstances exception is available to individual clinicians, groups, and virtual groups affected by the COVID-19 pandemic. If you were prevented from collecting data for an extended period of time, or if COVID-19 could affect your performance on cost measures, this exception is for you.

You can apply for an Extreme and Uncontrollable Circumstances exception for each of the four MIPS performance categories, including Quality, Cost, Improvement Activities, and Promoting Interoperability. CMS will allow applicants to select more than one performance category for an exception, and applicants can receive relief from QPP reporting in all four performance categories if needed. If you are approved for an exception, your score in the selected performance category or categories will be reweighted to 0% for the 2020 MIPS performance period. This effectively eliminates the performance category from your final MIPS score.

To receive a final score for the 2020 MIPS performance period and remain eligible for a positive payment adjustment in 2022, you must report data in at least two performance categories. If CMS approves your application for an exception for three or four performance categories, you will receive a final score equal to the performance threshold for the 2020 MIPS performance period. This means that you will not be eligible for a positive payment adjustment in 2022. Instead, you will receive a neutral payment adjustment.

The Extreme and Uncontrollable Circumstances exception application is open until December 31, 2020. CMS will approve exemption requests on a case-by-case basis. They will assess each applicant’s ability to submit data for each performance category selected in the application. CMS is not requiring documentation, but they suggest you retain documentation supporting your application in your own records in case CMS selects you for data validation or an audit. Third parties may apply on behalf of MIPS-eligible clinicians.

For more details about the application process, see the CMS 2020 QPP exception applications fact sheet.

How to Decide if You Should Apply for Relief

The Extreme and Uncontrollable Circumstances exception is most beneficial if you are unlikely to meet the MIPS performance thresholds or data reporting standards for the 2020 QPP reporting period. Your weight for each performance category with an approved exception will be set to 0%, effectively eliminating that category from your final MIPS score for 2020. If you receive an exception for more than two performance categories, you will be ineligible for a positive payment adjustment in 2022, and you will instead receive an automatic neutral payment adjustment.

If there is a chance you or your group can successfully meet 2020 MIPS performance thresholds in some or all performance categories, it is in your best interest to skip the Extreme and Uncontrollable Circumstances exception application process. If you do not request an exception or receive an exemption in just one or two performance categories, you will remain eligible for a positive payment adjustment in 2022, depending on your performance relative to the MIPS performance thresholds.

If you are considering applying for an exception to 2020 QPP reporting requirements, time is on your side. The deadline to apply for the Extreme and Uncontrollable Circumstances exception is December 31, 2020. It may be in your best interest to wait and see how your performance in the four required MIPS categories looks in the fall. Also, if you apply for an exception and later discover that you have met or exceeded the MIPS performance threshold, you may submit your data as normal, overriding your exception.

CMS may apply an automatic exception for individual clinicians located in a CMS-designated region affected by an extreme and uncontrollable event like a FEMA-designated major disaster. If you are located in one of these areas, all four performance categories will be reweighted to 0% unless you choose to submit data. Automatic exceptions will not apply to groups or virtual groups. To date, CMS has not designated any areas for automatic Extreme and Uncontrollable Circumstances exceptions. You can sign up to receive updates on automatic exceptions here.

Overall, you have three options to consider under the Extreme and Uncontrollable Circumstances exception:

  1. Apply for relief in any or all of the four performance categories, including Quality, Cost, Improvement Activities, and/or Promoting Interoperability. This option is best if you do not expect to meet performance thresholds or data reporting requirements.
  2. Participate fully in the 2020 MIPS performance period by submitting data for all four performance categories and maintaining eligibility for a positive payment adjustment. This option is best if you are likely to meet performance thresholds. 
  3. Wait to see how your performance stacks up in the fall before deciding whether to apply for an exception. This option is best if you are unsure of your 2020 performance.

How TempDev Can Help

If you or your group need help to decide whether to apply for an exception, TempDev can review the regulatory requirements and your unique situation to advise you on the best course of action. The QPP consultants at TempDev can also help you optimize workflows to meet or exceed MIPS performance measures, even during COVID-19. 

Call us at 888.TEMP.DEV, or contact us here to get started reviewing your 2020 QPP reporting options. 

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