MIPS Updates: 2021 PY PI Hardship, Other EUCs Available; Reweighting for 2020 PY Cost Performance Category to 0 | News | APMA
MIPS Updates: 2021 PY PI Hardship, Other EUCs Available; Reweighting for 2020 PY Cost Performance Category to 0

May 24, 2021

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Last week, CMS announced the following updates to the Merit-Based Incentive Payment System (MIPS):

  • 2021 performance year Promoting Interoperability (PI) Hardship Exception and other Extreme and Uncontrollable Circumstances (EUCs) Exception applications are now open; and
  • 2020 performance year Cost performance category reweighted to 0.

2021 PY PI Hardship and Other EUCs Available

Applications are now open for the MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exception for the 2021 Performance Year. The deadline to submit your applications to CMS is December 31, 2021.

PI Hardship Exception Eligibility: MIPS eligible clinicians, groups, and virtual groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception Application whether they are reporting traditional MIPS or the APM Performance Pathway. Exceptions are granted if they:

  • are a small practice;
  • have decertified EHR technology;
  • have sufficient internet connectivity;
  • face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues; or
  • lack control over the availability of CEHRT.

NOTE: If you are already exempt from submitting Promoting Interoperability data, you do not need to apply.

General EUC Eligibility

MIPS eligible clinicians, groups, and virtual groups may submit an application to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must:

  • cause you to be unable to collect information necessary to submit for a MIPS performance category;
  • cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for three months); and/or
  • impact your normal process, affecting your performance on cost measures and other administrative claims measures.

For 2021 MIPS PY information and updates, visit www.apma.org/MIPS2021.

2020 PY Cost Performance Category Reweighted to 0

Recognizing the ongoing COVID-19 PHE impact on clinicians, CMS is reweighting the cost performance category from 15 percent to 0 percent for the 2020 performance period. The 15-percent cost performance category weight will be redistributed to other performance categories in accordance with § 414.1380(c)(2)(ii)(D). See the table below for reweighting scenarios.

CMS examined the underlying data for 2020 and found that in comparison to prior years’ data, the volume of data available to calculate the scores for the cost measures had significantly decreased overall. As a result, CMS did not believe it could reliably calculate scores for the cost measures that would adequately capture and reflect the performance of MIPS eligible clinicians, for the following reasons:

  • A significant decrease in service utilization in 2020 demonstrates cost measures may not accurately characterize patient risk due to the lack of diagnosis information in the lookback periods used for risk adjustment.
  • Episodes with COVID-19 diagnoses generally have higher observed and risk-adjusted costs, indicating COVID-19 impacted service utilization and wasn’t sufficiently accounted for through risk adjustment.
  • The overall number of clinicians who met 2020 cost measure case minimums substantially decreased from prior performance years. A substantial portion of clinicians had episodes with COVID-19.

Clinicians do not need to take any action as a result of this decision because the cost performance category relies on administrative claims data.

MIPS Performance Category Weight Redistribution Policies Finalized for the 2020 Performance Period:

MIPS Performance Category Reweighting Scenario

Quality Category Weight

Cost Category Weight

Improvement Activities Category Weight

Promoting Interoperability Category Weight

No Additional Reweighting Applies

55%

0%

15%

30%

Reweight 2 Performance Categories

No Promoting Interoperability, No Cost

85%

0%

15%

0%

No Quality, No Cost

0%

0%

15%

85%

No Improvement Activities, No Cost

70%

0%

0%

30%


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