In a rush to complete regulatory activities before both the end of the year and the transition to an incoming Biden-Harris administration, the Centers for Medicare & Medicaid Services (CMS)—as well as other federal agencies—announced several administrative steps and final rules important to both nephrologists and other clinicians.
CMS announced that it is accepting the impact of COVID-19 as a condition for receiving an Extreme and Uncontrollable Circumstances exemption in the Merit-based Incentive Payment System (MIPS). MIPS is the largest quality payment program administered by CMS.
An Extreme and Uncontrollable Circumstances exemption would allow clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories due to the current COVID-19 public health emergency. In the past, these exemptions were usually associated with natural disasters, for example, when reporting requirements have been interrupted by hurricanes or wildfires. In addition to extending this option to clinicians and practices significantly affected by COVID-19, the agency is extending the application deadline for 2020 to Monday, February 1, 2021, at 8 p.m. Eastern Time.
MIPS is one of two payment tracks in CMS’ Quality Payment Program (QPP) along with Advanced Alternative Payment Models. MIPS is a mandatory quality pay-for-performance program, except for clinicians excluded due to certain criteria such as low volume of Medicare patients, where clinicians report their performance on four categories of measures: Quality, Promoting Interoperability, Improvement Activities, and Cost. In 2018, there were a total of 7120 nephrologists who identified in MIPS, according to the American Medical Association Physician Masterfile (December 2017). Excluding nephrologists who did not report MIPS data in 2018 for various reasons, the participating number was 6117.