MIPS and the Pandemic

We at HiQ extend our best wishes and hopes for all the many healthcare practices affected by the pandemic. We understand how many practices have no option but to shut down and lay off their staff temporarily. We realize how difficult this is emotionally and financially. We understand that the duration is uncertain and may be longer than expected.

We believe that while specialty care may not be critically urgent to patients during the initial pandemic quarantine period, care for many chronic and new conditions will certainly be necessary and become increasingly urgent later in 2020.

We believe that practices must plan how to prioritize and accommodate patients after re-opening, to change appointment scheduling and waiting room / waiting time policies as well as consider alternate means of providing care for some patients such as phone visits or home visits.

Over the weekend, CMS announced a number of accommodations:

• Allowing Medicare payments for telehealth or home visits so as not to require patients to travel to a healthcare facility;
• Extending the deadline for attesting 2019 MIPS performance, which has been moved to April 30;
• Providing an automatic 2019 MIPS exemption (with a neutral MIPS payment adjustment) for providers / groups not reporting by that April 30 deadline; and
• Disregarding Q1/Q2 (Jan. 1 through June 30, 2020) for MIPS Quality and Cost performance measures. (CMS has not yet finalized this or any other 2020 MIPS performance year accommodation – stay tuned for more)

Though not in any manner announced by CMS, HiQ speculates that later in the year CMS may offer a 2020 MIPS hardship exclusion (with a neutral MIPS payment adjustment) for small practices and/or any practice significantly affected by the pandemic for the second half of the year. Like other prior disaster exclusions, we expect this might allow practices to participate by reporting at least 2 performance categories, upon which they would receive a hopefully positive payment adjustment for the 2022 payment year. We do not believe CMS will simply cancel the 2020 MIPS performance year and award all providers a neutral payment adjustment for the 2022 payment, since this would have too large an impact on the CMS long term strategy for value-based reimbursement.

If fewer practices report 2020 MIPS performance (due to a possible pandemic MIPS exclusion), there may be more money available for those providers who opt to participate for the Additional Performance Adjustment (for exceptional performance at or above a MIPS Final Score of 85).

Assuming a practice shuts down temporarily, this provides the practice administrator and other practice leadership the time and opportunity to plan MIPS in a manner that might otherwise have been skipped or short-changed.

Since MIPS Improvement Activities should be about driving change in the practice and now there is an unmistakable need for change (how to re-open with the pandemic still a reality), there is a natural synergy between a serious approach to MIPS and overcoming the challenges of the pandemic.

HiQ’s MIPS Essentials service is unique in offering the HiQ Quality System, based on a structured Quality Improvement Program methodology and policy manual. The HiQ Quality System is harmonized with certain foundational MIPS Improvement Activities and allows HiQ clients to focus their MIPS Improvement Activities on goals such as improving their MIPS Quality, Cost and/or Interoperability performance; the HiQ Quality Improvement Program may equally effectively be used to drive changes within the practice to overcome the challenges of the pandemic.

HiQ’s MIPS Essentials services are normally provided remotely and are not impacted by the pandemic.
We can help you attest late for 2019 if you haven’t done so already.

We can work with you now, productively, during any shutdown time to plan a course of action for re-opening in such a manner as to receive credit for MIPS Improvement Activities. We believe firmly that there is an opportunity for practices to recoup the negative financial impact of the pandemic by optimizing their MIPS strategy for long-term benefit.

To show our solidarity with the financial stress that the pandemic will exert on practices as well as to reflect that CMS will not require reporting for the first half of the year, for new clients who sign up from today until June 30, we will waive our Quick Start fees and only charge for the second half of 2020; our standard annual pricing will resume for 2021 and beyond. Please sign up now to take advantage of this special offer.