2020 MIPS Submission Update

March 17th, 2021

Dear Trusted Sammy Clients:


ICS, part of the Modernizing Family, takes great pride in our commitment to continue to provide you with updates to assist you in monitoring your compliance and MIPS reporting obligations during these times of continuous change.

See an important notification regarding MIPS 2020 below. Please read it in its entirety to ensure you have all the information you need to make an informed decision on whether or not you should report MIPS for 2020. 

On Thursday February 25, 2021, the Center for Medicare and Medicaid Services (CMS) announced that they will be applying the MIPS automatic extreme and uncontrollable circumstances (EUC) policy to all MIPS eligible clinicians for the 2020 performance period.

What does this mean for you?

Individual clinicians, groups, and virtual groups that haven’t submitted data.

  • Individual MIPS eligible clinicians: You don’t need to take any additional action to qualify for the automatic EUC policy and should not submit data for the 2020 performance year unless you want to be scored with respect to such data. You will be automatically identified and will receive a neutral payment adjustment for the 2022 MIPS payment year unless (1) you submit data as an individual in 2 or more performance categories; or (2) your practice reports as a group by submitting data for one or more performance categories.
  • Groups: You don’t need to take any further action to qualify for the automatic EUC policy and should not submit data for the 2020 performance year unless you want to be scored with respect to such data. 

Individual clinicians, groups, and virtual groups that have submitted data.

  • Individual MIPS eligible clinicians that have submitted data for a single performance category (such as Medicare Part B Claims MIPS measures submitted throughout the 2020 performance period):
    • You don’t need to take any additional action to be eligible for the automatic EUC policy and should not submit data for the 2020 performance year unless you want to be scored with respect to such data.
    • You’ll be automatically identified and have all 4 performance categories reweighted to 0% and will receive a neutral payment adjustment for the 2022 MIPS payment year unless (1) you submit data for another performance category, or (2) your group submits data for one or more performance categories.

  • Individual MIPS eligible clinicians that have submitted data as an individual for 2 or 3 performance categories:
    • You’ll receive a MIPS final score and MIPS payment adjustment for the 2022 MIPS payment year based on the data you’ve submitted.
    • You’ll only be scored in the performance categories for which data are submitted.
    • You cannot submit an application to override previously submitted data.

  • Groups and virtual groups that have submitted data for a single performance category:
    • If you’re not able to complete data submission for other performance categories, you can submit an application to request reweighting in all 4 performance categories.
    • This includes small practices that were automatically scored as a group on Medicare Part B Claims measures submitted throughout the 2020 performance period.
    • If you don’t submit an application, your group will be scored in all performance categories unless you are eligible for reweighting in one or more performance categories.
    • If your application is approved and data isn’t submitted for another performance category, your MIPS eligible clinicians will receive a neutral payment adjustment for the 2022 MIPS payment year.

  • Groups and virtual groups that have submitted data for 2 or 3 performance categories:
    • Your MIPS eligible clinicians will receive a MIPS final score and MIPS payment adjustment for the 2022 MIPS payment year.
    • Your group will be scored in all performance categories unless you qualify for reweighting in one or more performance categories.
    • You cannot submit an application to override previously submitted data.

CMS is also reopening the MIPS EUC application for individual MIPS eligible clinicians, groups, virtual groups, and Alternative Payment Model (APM) Entities through March 31, 2021 at 8 p.m. ET. Please note that applications received between now and March 31, 2021 won’t override previously submitted data.


Please note that if you have submitted data in more than one category to Registry Clearinghouse or another MIPS qualified registry (e.g., Healthmonix), you may not be able to submit an application to override previously submitted data and may not receive an automatic EUC exception, even if you attempt to delete such data prior to March 31, 2021.  If you have already submitted data for more than one category, please consult with your qualified advisor to determine how best to proceed, as failure to complete your submission may have an adverse impact on your MIPS score.

For further information and to read the communication in its entirety, please visit qpp.cms.gov.

Sincerely,

The ICS Software Team