Deadlines approaching for Medicare alternative payment programs

The end of the year will bring several important deadlines for Medicare’s Quality Payment Program (QPP). Practices have until Dec. 31 to apply for an “extreme and uncontrollable circumstances” exception, or a “promoting interoperability” exception for the 2020 Merit-based Incentive Payment System (MIPS) performance year. That’s also the last day to submit a virtual group election for the 2021 performance year.

The MIPS extreme and uncontrollable circumstances exception provides relief to practices whose ability to collect and report data was hindered by circumstances beyond their control, including the COVID-19 Public Health Emergency (PHE). Practices can request reweighting of one or more MIPS performance categories. The Centers for Medicare & Medicaid Services (CMS) automatically gave the uncontrollable circumstances exception in the spring  for reporting 2019 performance year data because of COVID-19. but practices will have to apply for it for 2020 performance year data. Otherwise that data will be due March 31.

Practices that faced issues with their certified EHR can apply for the interoperability hardship exception. The exception covers situations such as when a practice’s EHR is de-certified during the performance year. Simply lacking a certified HER, however, does not qualify a practice for an exception.

Applications for exceptions can be submitted through the QPP Portal. If approved, it will be reflected in the QPP Participation Status Tool.

Virtual groups

Individual eligible clinicians and small practices (10 or fewer eligible clinicians) can choose to form a virtual group under the MIPS. That allows the participants to submit their data as a group, which can help practices that may otherwise struggle to be reliably measured because of small patient numbers. Additional information on how to apply is available in the Virtual Group Toolkit.

Some additional dates to keep in mind include:

• Jan. 1, 2021: first day of the 2021 performance year,
• Jan. 4, 2021-March 31, 2021: data submission window for the 2020 performance year,
• March 1, 2021: deadline for CMS to receive claims for quality performance category for the 2020 performance year.

Practices can use the 2021 Qualifying Alternative Payment Model Participant Quick Start Guide and 2021 MIPS Eligibility Decision Tree to determine if they want to participate in the QPP through an advanced alternative payment model (AAPM) or in MIPS. The qualifying participant thresholds are required by law to increase during the 2021 performance year. To participate and qualify for the AAPM bonus, eligible clinicians will need to receive at least 75% of payments through an AAPM or see at least 50% of patients through an AAPM. Changes to MIPS for 2021 will be finalized in the forthcoming 2021 Medicare Physician Fee Schedule Final Rule. CMS will also update its QPP Participation Status Tool throughout the year.

— Erin Solis, Manager of Practice and Payment, American Academy of Family Physicians