MIPS Program Flexibility Offered Due To The Pandemic

We have seen many changes this year due to the COVID-19 pandemic, MIPS being just one of many.

At the beginning of the year Medicare’s Merit-Based Incentive Payment System (referred to as MIPS) was in the spotlight. This payment program reports that it rewards clinicians with financial incentives for improving the quality of care in their clinics (as defined by the standards of the program). 2019 was the first year that PTs, OTs, and SLPs could participate. While MIPS participation was optional for a large majority of rehab therapists, some chose to opt into the program in an effort to increase Medicare reimbursements. Starting 2020 some clinicians were mandated to participate in this program. Recently the Centers for Medicare and Medicaid Services (referred to often as CMS) announced that due to the impact and spread of COVID-19 they recognize that there may be struggles to successfully reporting in 2020. On June 24, 2029 CMS reported that it would give 2020 MIPS reporters some flexibility.

As per CMS: “The COVID-19 pandemic has impacted all clinicians across the United States and territories. However, we recognize that not all practices have been impacted by COVID-19 to the same extent. For the 2020 performance year we will be using our Extreme and Uncontrollable Circumstances policy to allow clinicians, groups and virtual groups to submit an application requesting reweighting of one or more Merit-based Incentive Payment System (MIPS) performance categories due to the current COVID-19 public health emergency. Additionally, we have already introduced a new high-weighted COVID-19 clinical trials improvement activity which provides an opportunity for clinicians to receive credit in MIPS for the important work they are already doing across the country. We believe this approach maintains a balance of encouraging participation in the Quality Payment Program while still allowing those clinicians that are impacted by the public health emergency to have relief from program participation through the extreme and uncontrollable circumstances policy. We also continue to monitor the impact of the COVID-19 public health emergency on Shared Savings Program quality reporting for the 2020 performance year. For example, we recently indicated that at this time, we are not providing the CAHPS for ACOs final vendor list or the vendor authorization tool. We will provide additional information as it becomes available. We will continue to explore additional ways to reduce burden on clinicians and provide further support for continued participation where we can.”

CMS has opened up access to the 2020 Extreme and Uncontrollable Circumstances Application for MIPS participants. It is open through December 31, 2020. Using this application, participants (including individuals, groups, and virtual groups), can request reweighting of one or more MIPS performance categories to 0% due to hardship from extreme and uncontrollable circumstances (the pandemic). Applications will be reviewed on a case-by-case basis, and if approved, the performance categories included in the application are weighted at 0% and will not contribute to one’s final score (unless you submit MIPS data for the 2020 performance period). For PTs, OTs and SLPs this means requesting to reweight one or both of the two categories in which they are eligible to participate. 

MIPS participants can submit an Extreme and Uncontrollable Circumstances Application through the QPP website by following the instructions from CMS

  1. Register for a HARP account (i.e., an account through the QPP) if you don’t have one. 
  2. Sign in to the QPP website (at https://qpp.cms.gov/)
  3. Select “Exceptions Applications” in the navigation bar on the left side of the page.
  4. Select “Add New Exception.”
  5. Select “Extreme and Uncontrollable Circumstances Exception.”
  6. Complete and submit the application. 

If you report MIPS as a group, then you must submit one application for the entire group.  

In addition to this, CMS added a new high-weighted activity to the pool “to provide an opportunity for clinicians to receive credit in MIPS for the important work they are doing across the country.” For this, MIPS participants can receive credit for this activity in one of two ways: 

  • “A clinician may participate in a COVID clinical trial and have those data entered into a data platform for that study; or
  • A clinician participating in the care of COVID-19 patients may submit clinical COVID-19 patient data to a clinical data registry for purposes of future study.”

While rehab therapists can participate in reporting this activity, many will not meet the activity’s logistics criteria. Therapists who work in physician practices are the most likely candidates to be eligible to report this activity. As per CMS: Clinicians could also pair the new COVID-19 clinical trials activity with the existing participation in a 60-day or greater effort to support domestic or international humanitarian needs (IA_ERP_2) activity for full credit for the Improvement Activities performance category. We intend for this improvement activity to be applicable to MIPS eligible clinicians that are reporting their COVID-19 related patient data to a clinical data repository, such as Oracle’s COVID-19 Therapeutic Learning System and clinicians participating in clinical trials such as the COVID-19 clinical trials being conducted by the National Institutes of Health (NIH). Oracle has developed and donated a system to the U.S. government that allows clinicians and patients at no cost to record the effectiveness of promising COVID-19 drug therapies. (You can also refer to the 2020 MIPS Data Validation Criteria (ZIP) for additional examples of clinical data repositories and clinical trials.)

We have certainly seen a lot of change this year, and I suspect more will occur before we ring in 2021.



Each year more than 350,000 professionals advance their career with Elite Learning.