Should You Apply for a MIPS COVID-19 Exception?

In June, CMS announced that clinicians participating in the Quality Payment Program Merit-based Incentive Payment System (MIPS) for 2020 whose practice is being adversely affected by COVID-19 can apply to re-weight their performance categories through an exception.

The two exceptions available in PY 2020 are:

  • The Extreme and Uncontrollable Circumstances Exception
  • The MIPS Promoting Interoperability Performance Category Hardship Exception

The application period for both exceptions closes on December 31, 2020.

The Extreme and Uncontrollable Circumstances Exception

This exception is designed to help organizations cope with uncontrollable circumstances (such as natural disasters) and public health emergencies (such as COVID-19). To receive the exception, an organization must demonstrate circumstances that inhibit the ability to collect the necessary information for a MIPS performance category and meet at least one of the two conditions below:

• The inability to submit the performance information for a period of time
• The process of submission would affect regular operations, which in turn would impact performance on MIPS measures

The exception application process

This year, CMS began requiring an HCQIS Access Roles and Profile (HARP) account for exception submission. After signing into QPP, the exception application is located on the left navigation bar after login. (A QPP Access User Guide to register for a HARP account is located at )

You can check on the application status by signing into QPP and be notified of the application outcome by email. Approved organizations will see an eligibility profile on QPP, but it may not appear in the QPP Participation Status Tool until data submissions beginning in 2021.

Organizations that receive approval will not have to report the requested performance categories and the remaining categories will be re-weighted. Clinicians that submit information for two or more categories will receive a final score based on the data.

There are circumstances when automatic re-weighting can occur. If a provider (groups are ineligible) is located in a CMS-declared extreme and uncontrollable event zone, they will qualify for a weight adjustment and receive a neutral payment. As of June, no qualifying events were announced by CMS. To be informed when a qualifying event occurs, sign up for QPP updates.

Clinicians can earn credit for COVID-19 clinical trial participation

Physicians that participate in a range of clinical trial types and report findings to a clinical data repository or registry may be eligible to attest their participation and receive MIPS credit. According to a letter sent by CMS to physicians in April, “MIPS eligible clinicians who report this improvement activity will earn 20 points or half of the total 40 points needed to receive a maximum score in the MIPS Improvement Activities performance category.”

Proposed boost to the Complex Patient Bonus due to COVID

CMS is revising this QPP incentive in light of the additional complexity of treating patients with COVID. Clinicians and organizations may be able to earn up to 10 bonus points for 2020 (the prior maximum was five).

Expanded use of telehealth toward measures

Forty-two quality measures can be assessed using telehealth as an encounter tool, even if the entire measure cannot be completed virtually—as long as the whole measure is performed it can be included (for example, the patient receives a blood test after a telehealth encounter).

Examples of measures eligible for a telehealth encounter include:

  • Diabetes: Hemoglobin A1c (HbA1c) Poor Control (> 9%)
  • Cervical Cancer Screening
  • Breast Cancer Screening
  • Preventive Care and Screening: Influenza Immunization

Other eligible measures include:

  • Dementia: Cognitive Assessment
  • Depression Remission at Twelve Months
  • Adult Major Depressive Disorder (MDD): Suicide Risk Assessment
  • Child and Adolescent Major Depressive Disorder (MDD): Suicide Risk Assessment

Trying to keep up with MIPS categories, measures and reporting can be overwhelming – using the right partner for practice management software and billing makes it easy. Contact Virtual OfficeWare Healthcare Solutions today at (412) 424-2260 or visit to learn how we can help optimize MIPS, streamline claims, and maximize revenue.

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