COVID-19 Update: CMS announces relief for providers participating in quality reporting programs

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On March 22, 2020, the Centers for Medicare & Medicaid Services (CMS) announced that it is granting exceptions from certain reporting requirements and extensions for providers participating in Medicare quality reporting programs. In response to the COVID-19 (coronavirus) pandemic, CMS recognized that “quality measure data collection and reporting for services furnished during this time period may not be reflective of their true level of performance” and made changes impacting the following programs.

Provider programs
CMS extended the 2019 data submission deadline from March 31, 2020, to April 30, 2020, for the Merit-based Incentive Payment System (MIPS) and the Medicare Shared Savings Program (MSSP). 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 indicated that it is evaluating options for providing relief around participation and data submission for 2020 as well.

Hospital programs
CMS made changes impacting 11 programs, including the Ambulatory Surgical Center Quality Reporting Program, the Hospital-Acquired Condition Reduction Program, the Hospital Inpatient and Outpatient Quality Reporting Programs, and the Hospital Value-Based Purchasing Program. For all of these programs, CMS made deadlines for October 1, 2019, to December 31, 2019, (Q4) data submission optional. If the Q4 data is submitted, it will be used to calculate 2019 performance and payment. If it is not submitted, 2019 performance will be based on data from Q1 to Q3. For 2020, CMS will not count data from January 1, 2020, through June 30, 2020, (Q1-Q2) for performance or payment programs. Data does not need to be submitted for this time period.

Post-acute care programs
CMS extended or rescinded data submission requirements for six programs, including the quality reporting programs for home health, hospices, inpatient rehab facilities, long-term care hospitals and skilled nursing facilities. As with the hospital programs, CMS made Q4 2019 data submission optional, and it will not count data for Q1 toQ2 2020. CMS also announced the same changes for the Skilled Nursing Facility Value-Based Purchasing Program.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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