Merit-Based Incentive Payment System (MIPS): Applying for Exception
The Merit-Based Incentive Payment System (MIPS) is a system by which physicians receive merit-based payment adjustments through Medicare. This system is meant to incentivize improved physician performance by distributing either fines or bonuses based on achievement. Physicians eligible for participation in MIPS in 2020 must be of a clinician type included in MIPS, enrolled in MIPS prior to January 1st, 2018, and not a Qualifying APM Participant. In certain situations, physicians can receive an exception from the full requirements of MIPS.
A composite score is used to evaluate physician performance. The score is broken down into sections, including a quality score, promoting interoperability score, improvement activities score, and a cost score, each of which carries a specific weight. The final MIPS score is a sum of the weighted performance out of a hundred, plus a possible five additional points if criteria are met to include a complexity score. Positive or negative pay adjustments are determined based on this score.
In certain cases, it may not be possible for physicians to meet all the requirements of the MIPS. This is particularly true within the last year: many practices have had to make drastic adjustments and compromises due to the COVID-19 pandemic. In normal circumstances, failure to meet MIPS standards would result in a fine. However, there are two instances in which physicians may be eligible to apply for an exception.
The first exception available to clinicians is called “The Extreme and Uncontrollable Circumstances Exception.” This exception is applicable in cases where external stressors have compromised a physician’s ability to meet the minimum performance requirements. If an applicant successfully receives this exception, then the relative weights of each of the performance categories may be subject to adjustment. Any and all categories are eligible for adjustment upon request of the applicant. Additionally, some groups will be eligible for automatic re-weighting. For the 2020 performance period, the deadline to submit a COVID-related Extreme and Uncontrollable Circumstances Exception was extended to March 31st as an additional flexibility.
The second exception is titled the “Promoting Interoperability Hardship Exception,” and may be applicable to physicians and groups who meet one of the following criteria: are small practices, have decertified EHR technology, have insufficient internet connection, have suffered financial hardships, or lack access to certified EHR technology. If approved, the Promoting Interoperability performance category may be reweighed to zero percent.
In order to submit an application for an exception, physicians and/or groups will need to first establish an account through HCQIS Access Roles and Profile (HARP). After signing on with one’s credentials, the form to request an exception will be accessible. Applicants will be notified by email whether their request has been accepted or denied. Notably, one cannot submit an exception to override previously-submitted Performance Year 2020 data.
Given the extraordinary circumstances that have characterized 2020 and 2021, many physicians may once more need to consider applying for an MIPS exception. It is highly advisable that individuals and small groups take advantage of any deadline extensions in order to qualify for the reweighting of performance categories. For further information on how and when to apply for an MIPS exception, visit https://qpp.cms.gov/mips/exception-applications.