Responding to the request of clinicians who are overburdened with the impact COVID-19 has had on the healthcare system, the Centers for Medicare & Medicaid Services (CMS) has announced some regulatory relief for those participating in in Medicare quality reporting programs.
Specifically, CMS announced this weekend that it is granting exceptions from reporting requirements and extensions for clinicians and providers participating in Medicare quality reporting programs with respect to upcoming measure reporting and data submission for those programs. Federal officials noted that 1.2 million clinicians currently participate in the Quality Payment Program under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), designed to reward providers for the quality of care they provide.
Earlier this month, the American College of Emergency Physicians asked CMS to delay all regulatory requirements and deadlines for Medicare healthcare professionals. They noted that “Emergency physicians and other healthcare professionals are spending all their time and attention dealing with the COVID-19 crisis and do not have the capacity to meet the specific regulatory requirements, including their reporting obligations, under CMS’ quality performance programs.”
Similarly, several other prominent industry organizations recently asked leaders in Congress and the Trump administration in a letter to act quickly to ensure clinicians focused on value-based care are not inappropriately penalized for the extreme costs of handling the COVID-19 pandemic and can continue to focus their energy on patient care.
Some of the groups’ specific requests were related to ACOs; because ACOs are judged against their spending from previous years, they could spend well more than their pre-determined spending targets in 2020 as they see spikes in hospitalizations and prolonged ICU stays of their ACO patients because of COVID-19, they said. For example, the organizations want the government to hold clinicians harmless from performance-related penalties for 2020, particularly those in two-sided risk alternative payment models (APMs).
“Clinicians in value-based arrangements face even higher levels of financial risk as a direct result of COVID-19,” the letter to CMS Administrator Seema Verma stated. “Any resources they spend to mitigate the spread of COVID-19 will cost them twice, once at the onset and again when spending is evaluated at year end in the context of their value-based performance.”
Some relief provided
Now, for clinicians reporting in MIPS, the Merit-based Incentive Payment System (MIPS) and Medicare Shared Savings Program accountable care organizations (MSSP ACOs), CMS has pushed back the 2019 data submission deadline from March 31 to April 30. MIPS-eligible clinicians who have not submitted any MIPS data by April 30, 2020 will qualify for the automatic extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year, CMS said, adding that it’s still evaluating options for providing relief around participation and data submission for 2020.
CMS did not make any relief announcements related to alternative payment model (APM) participants, but said it will “continue monitoring the developing COVID-19 situation and assess options to bring additional relief to clinicians, facilities, and their staff so they can focus on caring for patients.”
Other 2019 Q4 data submission deadlines for reporting programs such as the Hospital-Acquired Condition Reduction Program, Hospital Inpatient and Outpatient Quality Reporting Programs, Hospital Readmissions Reduction Program, Hospital Value-Based Purchasing Reduction Program, and a slew of others, have been made optional.
If the participant does choose to submit that data, it will be used to calculate the 2019 performance and payment (where appropriate). If data for Q4 is unable to be submitted, the 2019 performance will be calculated based on data from January 1, 2019 – September 30, 2019 (Q1-Q3) and available data, CMS stated.
Verma stated in her announcement, “In granting these exceptions and extensions, CMS is supporting clinicians fighting Coronavirus on the front lines.”
A full list of the programs and the relief CMS has provided can be viewed here.
For those programs with data submission deadlines in April and May 2020, submission of those data will be optional, based on the facility’s choice to report. In addition, no data reflecting services provided January 1, 2020 through June 30, 2020 will be used in CMS’s calculations for the Medicare quality reporting and value-based purchasing programs. This is being done to reduce the data collection and reporting burden on providers responding to the COVID-19 pandemic, the federal agency stated.
“CMS recognizes that quality measure data collection and reporting for services furnished during this time period may not be reflective of their true level of performance on measures such as cost, readmissions and patient experience during this time of emergency and seeks to hold organizations harmless for not submitting data during this period,” officials said.
