CMS Reweights 2020 MIPS Cost Category; Apply Now for 2021 MIPS Hardship Exceptions; 2018-2019 Cost Measure Benchmark Files Released

May 25, 2021

The Centers for Medicare & Medicaid Services (CMS) recently announced updates to the Merit-based Incentive Payment System (MIPS) under the Quality Payment Program (QPP). The agency reweighted the 2020 MIPS cost performance category, opened applications for the 2021 MIPS promoting interoperability performance category hardship and extreme and uncontrollable circumstances exceptions, and released MIPS Cost measure benchmarks. Additional details include the following:

2020 MIPS Cost Performance Category Reweighted to Zero Percent

CMS is reweighting the cost performance category in MIPS to 0% from the originally required 15% for the 2020 MIPS performance period (2022 MIPS payment year).

The 15% cost performance category weight will be redistributed to other performance categories. The table below shows reweighting scenarios for the 2020 performance period.

MIPS Performance Category Reweighting Scenario

Quality Category Weight

Cost Category Weight

Improvement Activities Category Weight

Promoting Interoperability Category Weight

No Additional Reweighting Applies

55%

0%

15%

30%

Reweight 2 Performance Categories

No Promoting Interoperability, No Cost

85%

0%

15%

0%

No Quality, No Cost

0%

0%

15%

85%

No Improvement Activities, No Cost

70%

0%

0%

30%

CMS is taking this action because the agency’s analysis of the 2020 performance year data, in comparison to prior years, shows that the volume of data available to calculate the scores for the cost measures has significantly decreased. As a result, CMS does not believe it can calculate scores for the cost measures that would adequately capture and reflect the performance of MIPS eligible clinicians.

Clinicians do not need to take action, as the cost performance category relies on administrative claims data.

This reweighting of the cost performance category applies in addition to the extreme and uncontrollable circumstances (EUC) policies. Clinicians who aren’t covered by the automatic EUC policy or who did not apply to request reweighting under the EUC policy will still have their cost performance category weighted to 0%.

Applications for the 2021 MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exceptions are Open

Applications are now open for the MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exception for the 2021 Performance Year. Applications are due to CMS by December 31, 2021.

Promoting Interoperability Hardship Exception

MIPS eligible clinicians, groups, and virtual groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception Application whether they’re reporting traditional MIPS or the new APM Performance Pathway (APP). Exceptions are granted if they:

  • Are a small practice;
  • Have decertified electronic health record (EHR) technology;
  • Have insufficient Internet connectivity;
  • Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues; or
  • Lack control over the availability of certified electronic health record technology (CEHRT).

Those already exempt from submitting Promoting Interoperability data do not need to apply.

MIPS eligible clinicians and groups with MIPS eligible clinicians participating in a MIPS APM can apply for Promoting Interoperability hardship exceptions and qualify for automatic reweighting just like other MIPS eligible clinicians. Those participating as an APM entity will receive the APM Entity’s score but will be excluded from the calculation when CMS creates an average Promoting Interoperability score for the APM Entity.

Extreme and Uncontrollable Circumstances Exception

MIPS eligible clinicians, groups, and virtual groups may apply to reweight any or all MIPS performance categories if they have been affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must:

  • Cause an inability to collect information necessary to submit data for a MIPS performance category;
  • Cause an inability to submit information that would be used to score a MIPS performance category for an extended period of time (for example, an inability to collect data for the quality performance category for 3 months), and/or;
  • Impact normal processes, affecting performance on cost measures and other administrative claims measures.

APM entities participating in MIPS APMs may also submit an Extreme and Uncontrollable Circumstances Exception Application that includes differences from the existing policy for individuals, groups, and virtual groups:

  • APM Entities are required to request reweighting for all performance categories.
  • At least 75% of an APM Entity’s MIPS eligible clinicians must qualify for reweighting in the Promoting Interoperability performance category.
  • Data submission for an APM entity will not override performance category reweighting.

For more information and to apply see the About QPP Exceptions page on the QPP website. The 2021 MIPS Promoting Interoperability Hardship Exception Application Guide and the 2021 Extreme and Uncontrollable Circumstances Exception Application Guide are also available in the QPP Resource Library.

MIPS Cost Measure Benchmarks Now Available

In April, the Association for Clinical Oncology (ASCO), the American Medical Association (AMA), and more than 40 other national medical specialty societies sent a letter to CMS urging the agency to immediately release MIPS cost benchmarks. This action was needed to increase transparency around the cost performance category—including how CMS evaluates performance in the category. Data for 2018 and 2019 has since been released is available to download.  

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