New Changes Apply to CMS’ Merit-based Incentive Payment System (MIPS) in Response to COVID-19

New Changes Apply to CMS’ Merit-based Incentive Payment System (MIPS) in Response to COVID-19

MIPS categories

Since the COVID-19 pandemic hit last year, we have been keeping our pulse on changes and updates to value-based program requirements. Here are three of the recent policy updates that apply to providers and groups participating in Centers for Medicare and Medicaid Services (CMS) Merit-based Incentive Payment System (MIPS).

#1 Cost Reweighting

The most significant change to MIPS 2020 performance year was the elimination of the cost performance category. Health care last year was unique. It has been a massive undertaking for providers and groups to respond to the global pandemic. CMS recognizes that urgent service delivery has been the priority. As there has been inadequate capture of cost data and performance rates would be impacted, CMS has reweighted the cost performance category from 15% to 0%. This change applies to all MIPS eligible clinicians, whether participating as an individual, group, or virtual group.

“Our analysis of the underlying data for the 2020 performance year, in comparison to prior years’ data, shows that the volume of data available to calculate the scores for the cost measures has significantly decreased overall, as a result, we do not believe we can reliably calculate scores for the cost measures that would adequately capture and reflect the performance of MIPS eligible clinicians”
– CMS stated in a Quality Payment Program email sent earlier this summer

This 15% of cost performance weight will be redistributed in other category weights.

Of note, this change is automatically applied. Providers and groups do not need to take on any action for this change to apply since the cost category is calculated from administrative claims data.

Moving to performance year 2021, there have been several proposed changes and flexibilities. Most importantly, there are two changes that have been finalized and they both are in form of exceptions. For performance year 2021, there are two exception applications available to clinicians and both due by December 31st, 2022.

#2 Extreme and Uncontrollable Circumstance Exception

MIPS participating providers have always been able to apply for Extreme and Uncontrollable Circumstance Exception (EUC) to request reweighting of performance categories when faced with a paramount circumstance. COVID-19, a public health emergency, falls into this category. For the 2020 performance year, CMS automatically applied EUC to all MIPS eligible clinicians reporting as individuals, not groups or virtual groups. This means that all categories were weighted to 0% for a neutral payment adjustment in 2022, unless a provider submitted data for a performance category. For performance year 2021, CMS encourages providers and groups to continue to use the EUC policy if they are being significantly impacted by the pandemic.

#3 Promoting Interoperability Hardship Exception

The Promoting Interoperability performance category of MIPS promotes use of certified electronic health record technology to enable a fully connected health care system that empowers patients, caregivers, and their providers. Typical requirements include objectives surrounding ePrescribing, Health Information Exchange Bi-Directional Exchange, Public Health Registry Reporting and more to calculate the 25% weighting of this performance category.

Beginning in 2021, MIPS providers and groups may submit a MIPS Promoting Interoperability Performance Category Hardship Application. A few of the specific reasons to seek hardship include:

  • You have decertified EHR technology
  • You have insufficient internet connectivity
  • You lack control over the availability of CEHRT*

More hardship exception reasons are found on the QPP website.

*Simply lacking the required CEHRT doesn’t qualify you for reweighting

If your application gets accepted, the 25% weighting of the Promoting Interoperability category will be redistributed to another performance category or categories. However, if you submit data for this category, the hardship application will be cancelled, and the submitted data will evaluated for scoring.

What’s Next?

One year ago, we were all racing to respond and manage the pandemic. Today, we are faced with a new public health reality with oscillating impacts. It is requiring us to redefine the next generation of service delivery, innovation, and improvement. With that in mind, we plan on releasing even more quality features in the second half of this year to help reduce your data burdens and facilitate insights for improved health care.


Renee Towne

About the Author
Renee Towne
Director of Quality Programs at KPI Ninja, Inc.
Renee provides operational leadership of quality initiatives at KPI Ninja. Towne has a background in occupational therapy, education and experience in operational excellence across a variety of healthcare domains. Based on prior experience as a clinician that drove outcomes patient by patient, she is leaving a larger footprint by improving health care more comprehensively, population by population.


About KPI Ninja
KPI Ninja is a data analytics company that helps healthcare organizations accelerate their quality, safety, and financial goals with a unique combination of software and service. We are differentiated by our signature mix of technology, performance management consulting and healthcare expertise. We don’t merely offer software solutions but work shoulder to shoulder with clients to help them draw on the power of analytics and continuous improvement methodologies to become more efficient. In harmony with our data-centered ethos, we truly believe that our success is strongly co-related with yours.

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