Reminder: PY2020 Performance Category Reweighting Requests Due to COVID-19 Will Be Accepted Through November 29, 2021
The COVID-19 pandemic continues to impact all clinicians across the United States and territories, and CMS recognizes that not everyone may have been able to submit an Extreme and Uncontrollable Circumstances (EUC) Exception Application for performance year (PY) 2020 before the March 31, 2021, deadline. As part of CMS’ ongoing support for clinicians who are on the front lines of this public health emergency (PHE), they are allowing clinicians, groups, virtual groups, and Alternative Payment Model (APM) Entities to request Merit-based Incentive Payment System (MIPS) performance category reweighting for PY2020 under CMS EUC policy through November 29, 2021, at 8:00 PM ET.
Who Can Request Reweighting?
While any clinician, group, virtual group or APM Entity can request performance category reweighting during this time period due to the COVID-19 PHE, the following types of groups in particular may want to consider submitting a request:
- Small practices that reported Medicare Part B claims measures for the quality performance category but didn’t report group-level data for other performance categories. Some small practices may not have fully understood the implications of their PY2020 claims reporting in the context of some of the PY2019 policies CMS introduced at the onset of the COVID-19 PHE. As a result, these small practices may wish to request performance category reweighting on behalf of the entire group.
- Virtual groups that weren’t able to submit an EUC application by the March 31 deadline for their PY2020 data due to the ongoing COVID-19 PHE. Clinicians who were approved to participate as a virtual group will be scored as a virtual group, regardless of data submission. Some virtual groups with clinicians on the front lines of the COVID-19 PHE may have missed the March 31 deadline for submitting an EUC Exception Application or were unaware that the automatic EUC policy didn’t apply to their MIPS-eligible clinicians.
How Does Performance Category Reweighting Work?
In accordance with CMS EUC policies for individuals, groups, and virtual groups, CMS won’t reweight any performance category for which they’ve received data. This applies to clinicians who report as individuals and are covered by CMS automatic EUC policy and to groups and virtual groups that request and receive reweighting. Please note that when fewer than 2 performance categories are scored (for example, one category is weighted at 100% of the final score, and the others are weighted at 0%), the clinician or group will earn a PY2020 final score equal to the performance threshold and the MIPS-eligible clinician(s) will receive a neutral payment adjustment in PY 2022, unless a higher final score is available. As a reminder, CMS reweighted the cost performance category to 0% for all clinicians, groups, and virtual groups in PY2020.
- Example: A small practice received a group score in the quality performance category from reporting Medicare Part B claims measures under CMS existing policies. The quality performance category can’t be reweighted because they’ve received data. However, if the improvement activities and Promoting Interoperability performance categories were approved for reweighting to 0% (and no data was submitted for either of those categories), the quality performance category would be weighted at 100% of the final score. As a result, the group would receive a final score equal to the performance threshold and the MIPS-eligible clinician(s) in the group would receive a neutral payment adjustment in PY2022, unless a higher final score is available.
In accordance with CMS EUC policies for APM Entities, data submission for an APM Entity won’t override performance category reweighting. If approved, the MIPS-eligible clinicians in the APM Entity will receive a score equal to the performance threshold and a neutral MIPS payment adjustment in the 2022 payment year.
How Can I Request PY2020 Performance Category Reweighting?
Due to technical limitations, CMS is unable to reopen the 2020 EUC Exception Application form in CMS systems. Because of these technical limitations, CMS is allowing stakeholders to submit 2020 EUC reweighting requests through the Targeted Review form until November 29, 2021. You can access this form by signing in to qpp.cms.gov. (The EUC Exception Application form currently accessible when you sign in to qpp.cms.gov is for PY2021 applications only. Don’t use the Exception Application form to request PY2020 reweighting.)
When using the Targeted Review form to submit an EUC reweighting request for PY2020, you’ll need to:
- Select the performance categories for which you’re requesting reweighting.
- 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, CMS encourages you to reiterate the performance categories for which you are requesting reweighting: quality, improvement activities, and/or Promoting Interoperability.)
Please review 2020 Extreme and Uncontrollable Circumstances: Reweighting Requests Extension Guide for step-by-step instructions with screenshots.
What About Automatic EUC Performance Category Reweighting?
CMS applied their automatic EUC policy to all individual MIPS-eligible clinicians for PY2020. Under this policy, CMS reweighted to 0% any performance category for which data wasn’t submitted, and these performance categories don’t contribute to the clinician’s individual final score. However, the automatic EUC policy only applies to those clinicians who were eligible to participate in MIPS as individuals; it doesn’t apply to clinicians who were only eligible to participate as a group or APM Entity, or who elected to participate as a virtual group.
There’s no need to request reweighting for PY2020 for a clinician who was eligible to participate in MIPS as an individual because they’ve already applied reweighting under the automatic EUC policy.
Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at QPP@cms.hhs.gov, Monday-Friday 8:00 AM- 8:00 PM ET. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 AM and after 2:00 PM ET.
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