The Centers for Medicare and Medicaid Services (CMS) recently announced it has reopened its reweighting request period for the 2020 MIPS performance year due to the ongoing impact of the COVID-19 pandemic. Clinicians, groups, virtual groups, and Alternative Payment Model (APM) Entities may request MIPS performance category reweighting for 2020 under the Extreme and Uncontrollable Circumstances (EUC) policy now through November 29, 2021, at 8 p.m. ET. All clinicians should carefully review their final individual and group-level MIPS scores and payment adjustment information as some clinicians are receiving a penalty if their practice coded Medicare Part B claims in 2020.
Background
CMS applied its automatic EUC policy to all individual MIPS eligible clinicians in 2020 to reweight to 0% any performance category for which those clinicians did not submit any MIPS data. However, the automatic EUC policy only applied to clinicians who were eligible to participate in MIPS as individuals. The automatic EUC did not apply to clinicians that were not MIPS eligible at the individual level but were eligible to participate as a group, virtual group, or an APM entity.
If a practice coded Medicare Part B claims for 2020, those claims were scored at both the individual clinician level and as a group. This means that individual clinicians who were not individually eligible, but were eligible as a group, could receive a negative payment adjustment in payment year 2022 for Medicare Part B claims that were scored for the group.
The table below illustrates examples of how two clinicians in the same practice could be impacted based on Medicare Part B claims submissions.
| Clinician MIPS Eligibility | 2020 MIPS Reporting Actions | 2020 MIPS Individual Score | 2020 MIPS Group Score | Automatic EUC for MIPS Eligible Clinicians | 2022 MIPS Penalty |
|---|---|---|---|---|---|
Dr. Jane Doe Practice A
| Dr. Jane Doe was required to report MIPS at the individual level. She submitted a few claims with MIPS G-codes at the beginning of 2020, but she stopped reporting MIPS in the middle of 2020 due to Covid-19. | QPP calculates an individual MIPS score based on the claims submissions: 10 MIPS points. | QPP calculates a group MIPS score based on the claims submissions: 10 MIPS points. | Applies. The EUC changed the individual MIPS score of 10 points into a neutral score (45 MIPS points). The individual score of 45 MIPS points is higher than the group score of 10 MIPS points and became the final MIPS score. | No penalty. |
Dr. Jane Smith Practice A
| Dr. Jane Smith didn’t report 2020 MIPS because she was not MIPS eligible at the individual level. | No individual MIPS score. | QPP calculates a group MIPS score based on claims submissions: 10 MIPS points. | The automatic EUC does NOT apply to group scores. This clinician receives the final group score of 10 MIPS points. | -7% penalty. Submit 2020 EUC reweighting request through the Targeted Review form by 11/29/2021 to remove the group score and penalty. |
Check Final MIPS Scores and Payment Adjustments
Clinicians should check their MIPS performance feedback and review both their individual and group-level scores to determine if any non-eligible individual clinicians in their practice have been impacted by this situation. MIPS performance feedback reports are available from CMS, but MDinteractive can assist clinicians with accessing their reports and interpreting the results if they have an MDinteractive account.
- If you previously granted us permission to access your reports, we have already uploaded them to your MDinteractive account. Just click the green “QPP Performance Feedback” icon on your 2021 MIPS dashboard then click “2020 QPP Feedback” to view your 2020 results now.
- If you have not already given us access, simply log into your MDinteractive account, click the blue or yellow "QPP Performance Feedback" icon on your dashboard and complete the steps.
Submit Request for EUC Reweighting - Take Action Now
If a clinician is receiving a low group-level final score (e.g., below 45 points) and a subsequent negative payment adjustment he or she should submit a 2020 performance category reweighting request. CMS is allowing clinicians to submit 2020 EUC reweighting requests through the Targeted Review form until 11/29/2021.
Clinicians should follow the steps below to submit a 2020 EUC reweighting request through the Targeted Review form before the CMS deadline:
- Sign in to your QPP account.
- Open the Targeted Review form.
- Select the Performance Categories for which you’re requesting reweighting (Quality, Promoting Interoperability, and Improvement Activities).
- Select “Extreme and uncontrollable circumstances” in the Issue Selection.
- State explicitly in the Description that you’re submitting an EUC application due to the continuing COVID-19 PHE. (In addition, we encourage you to reiterate the performance categories for which you are requesting reweighting: quality, improvement activities, and/or Promoting Interoperability.)
More information can be found in the CMS 2020 Extreme and Uncontrollable Circumstances: Reweighting Requests Extension Guide (PDF) for step-by-step instructions with screenshots.
More Questions?
CMS is accepting 2020 performance category reweighting requests due to COVID-19 through 11/29/2021. Contact one of our MIPS specialists today if you need help reviewing your 2020 MIPS final scores and payment adjustment information or have questions about requesting the 2020 EUC reweighting for your practice.
2020 MIPS Score 2022 MIPS Payment Adjustment Targeted Review MIPS Reweighting Extreme and Uncontrollable Circumstances
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