Medicare Compliance & Reimbursement
CMS Offers COVID-19 Relief for QPP Participants
Know the extreme and uncontrollable circumstances policy update. The feds realize that clinicians are battling the 2019 novel coronavirus (COVID-19) in hospitals across the nation. Plus, they understand that the last things providers want to worry about are administrative burdens and impending deadlines during a pandemic. Now: On March 22, the Centers for Medicare & Medicaid Services (CMS) offered Quality Payment Program (QPP) participants an administrative olive branch. The agency extended the deadline for 2019 Merit-Based Incentive Payment System (MIPS) measures’ submissions to April 30, 2020. Plus, CMS gave hospitals and post-acute care programs (PACs) a break, making Q4 quality data submissions — Oct. 1, 2019 to Dec. 31, 2019 — optional. Here’s Why the Feds Eased Up on QPP Requirements While many MIPS-eligible clinicians (ECs), hospitals, and PACs are entrenched in the fight against COVID-19 and caring for sick patients, there’s no way for them to collate data and submit accurate QPP information. “CMS recognizes that quality measure data collection and reporting for services furnished during this time period may not be reflective of their true level of performance on measures such as cost, readmissions and patient experience during this time of emergency and seeks to hold organizations harmless for not submitting data during this period,” acknowledges the agency in a release. “In granting these exceptions and extensions, CMS is supporting clinicians fighting Coronavirus on the front lines,” stresses CMS Administrator Seema Verma in a release. “The Trump Administration is cutting bureaucratic red tape so the healthcare delivery system can direct its time and resources toward caring for patients.” Know These MIPS Updates In addition to MIPS ECs, Medicare Shared Savings Program Accountable Care Organizations (ACOs) will also have until April 30 to submit 2019 MIPS measures. If your organization is struggling, and you know the new deadline will be impossible to meet — that’s OK. If you choose not to submit as a MIPS EC, you’ll automatically qualify for the “extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year,” CMS says. But: However, if you do end up submitting measures as an individual in two or more MIPS categories — Quality, Improvement Activities, and/or Promoting Interoperability — or you’re “part of a group that submits data on behalf of its clinicians,” your performance categories will be reweighted and you could receive a positive or negative 2021 payment adjustment. The Cost performance category is weighted at 0 percent under an automatic extreme and uncontrollable circumstances policy and doesn’t factor into adjustments, reminds the QPP COVID-19 response fact sheet. Find the measures/payment breakdown in Appendix A of the QPP COVID-19 fact sheet at https://qpp-cm-prod-content.s3.amazonaws.com/uploads/966/QPP COVID-19 Response Fact Sheet.pdf. Important: CMS plans to review options and offer guidance on 2020 QPP measures submissions and incentives in the months ahead. See New 2019 QPP Submission Changes for Hospitals and PACs According to new guidance, Q4 submissions are optional for hospital and PACs under the new Medicare updates; however, you can still send your quality data. “If Q4 is submitted, it will be used to calculate the 2019 performance and payment (where appropriate),” explains the agency. Hospital and PAC data from Jan. 1, 2020 to June 30, 2020 (Q1-Q2) won’t be used as a qualifying requirement for the QPP participants. Consequently, hospitals and PACs don’t need to submit quality data for this time period at all, indicates the release. “In addition, no data reflecting services provided January 1, 2020 through June 30, 2020 will be used in CMS’ calculations for the Medicare quality reporting and value-based purchasing programs,” CMS says. AMA Weighs In Industry organizations agree that CMS did the right thing by pushing back deadlines for providers, who are already strapped and struggling due to the pandemic. “CMS’ decision to offer relief from the submission demands in the Quality Payment Program will be felt immediately. Doctors don’t have much time to breathe a sigh of relief, but if they did, they would take a moment to thank CMS for this wise decision,” says Patrice A. Harris, MD, MA, president of the American Medical Association (AMA) in a release. Resources: Review the QPP release and charts at www.cms.gov/newsroom/press-releases/cms-announces-relief-clinicians-providers-hospitals-and-facilities-participating-quality-reporting and see the CMS memorandum on the changes at www.cms.gov/files/document/guidance-memo-exceptions-and-extensions-quality-reporting-and-value-based-purchasing-programs.pdf.
Medicare Compliance & Reimbursement
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