On March 22, 2020, the Centers for Medicare & Medicaid Services (CMS) implemented substantial administrative relief for clinicians, providers and facilities participating in Medicare quality reporting programs, including widely implemented programs like Medicare Shared Savings Program Accountable Care Organizations (ACOs) and the Merit-based Incentive Payment System (MIPS). These measures include extensions of deadlines and delays in reporting requirements for certain quality programs in order to alleviate the administrative burden on health care providers during the COVID-19 crisis. For example, CMS believes that approximately 1.2 million clinicians enrolled in ACOs and MIPS alone will have more time and resources to care for COVID-19 patients because of this administrative reduction.
The following changes, which are also summarized here, are effective immediately:
(1) Quality Payment Programs (QPPs)
- Merit-based Incentive Payment System (MIPS)
- Medicare Shared Savings Program Accountable Care Organizations (ACOs)
The deadlines for 2019 data submission for these two QPPs are extended from March 31, 2020, to April 30, 2020. 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 is further evaluating options for 2020 participation and data submissions.
(2) Hospital Programs
- Ambulatory Surgical Center Quality Reporting Program
- CrownWeb National ESRD Patient Registry and Quality Measure Reporting System
- End-Stage Renal Disease (ESRD) Quality Incentive Program
- Hospital-Acquired Condition Reduction Program
- Hospital Inpatient Quality Reporting Program
- Hospital Outpatient Quality Reporting Program
- Hospital Readmissions Reduction Program
- Hospital Value-Based Purchasing Program
- Inpatient Psychiatric Facility Quality Reporting Program
- PPS-Exempt Cancer Hospital Quality Reporting Program
- Promoting Interoperability Program for Eligible Hospitals and Critical Access Hospitals
The deadlines for October 1, 2019 – December 31, 2019 (Q4) data submissions are now optional. If Q4 is submitted, 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 other available data. CMS will also not count data from January 1, 2020 through June 30, 2020 (Q1-Q2) for performance or payment programs, and this data does not need to be submitted to CMS. However, for the Hospital-Acquired Condition Reduction Program, if data from January 1, 2020 – March 31, 2020 (Q1) is submitted, it will be used for scoring in the program (where appropriate).
(3) Post-Acute Care Programs
- Home Health Quality Reporting Program
- Hospice Quality Reporting Program
- Inpatient Rehabilitation Facility Quality Reporting Program
- Long-Term Care Hospital Quality Reporting Program
- Skilled Nursing Facility Quality Reporting Program
- Skilled Nursing Facility Value-Based Purchasing Program
The deadlines for October 1, 2019 – December 31, 2019 (Q4) data submissions are optional. If Q4 is submitted, it will be used to calculate the 2019 performance and payment (where appropriate). Data from January 1, 2020 through June 30, 2020 (Q1-Q2) does not need to be submitted to CMS for purposes of complying with quality reporting program requirements. Further, for Home Health and Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS), survey data from January 1, 2020 through September 30, 2020 (Q1-Q3) does not need to be submitted to CMS. In addition, For the Skilled Nursing Facility (SNF) Value-Based Purchasing Program, qualifying claims will be excluded from the claims-based SNF 30-Day All-Cause Readmission Measure (SNFRM; NQF #2510) calculation for Q1-Q2.
All clinicians, providers and facilities enrolled in quality reporting programs should examine these new guidelines and plan accordingly.
Opinions and conclusions in this post are solely those of the author unless otherwise indicated. The information contained in this blog is general in nature and is not offered and cannot be considered as legal advice for any particular situation. The author has provided the links referenced above for information purposes only and by doing so, does not adopt or incorporate the contents. Any federal tax advice provided in this communication is not intended or written by the author to be used, and cannot be used by the recipient, for the purpose of avoiding penalties which may be imposed on the recipient by the IRS. Please contact the author if you would like to receive written advice in a format which complies with IRS rules and may be relied upon to avoid penalties.
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