In response to the coronavirus (COVID-19) crisis, the Centers for Medicare and Medicaid Services (CMS) has announced relief provisions that extend the Merit-based Incentive Payment System (MIPS) deadline from March 31, 2020 to April 30, 2020 for MIPS-eligible clinicians and allow all non-reporting clinicians to automatically fall under the hardship exemption to receive a neutral payment adjustment.
CMS released a fact sheet with additional guidance related to its COVID-19 response, including important clarifications about how to qualify for its extreme and uncontrollable circumstances hardship exemption.
As previously stated, MIPS-eligible clinicians who report no data for 2019 MIPS will automatically receive the hardship exemption and thus a neutral payment adjustment for the 2021 payment year. This automatic exemption will also apply to individual clinicians who have only submitted data for one MIPS performance category (quality, promoting interoperability or improvement activities). The deadline for this application is currently set for April 30, 2020.
If a MIPS-eligible clinician submits data for two or more performance categories, or if they submit any MIPS data as part of a group, they will be scored on those categories unless they specifically apply for the hardship exemption. In other words, the exemption would not be automatic in these cases, and the individual or group would still be eligible to receive a payment adjustment.