COVID-19: Clinicians get reprieve on data reporting for Medicare quality payment programs

Crystal Yednak Senior Manager, Health Research Institute, PwC US March 27, 2020

With some deadlines drawing near, CMS this week granted exceptions and extensions from reporting requirements and data submissions for Medicare quality payment programs, citing extreme and uncontrollable circumstances due to the COVID-19 pandemic.

For providers in the Merit-based Incentive Payment System (MIPS) and Medicare Shared Savings Program for Accountable Care Organizations (ACOs), the 2019 data submission deadline was extended from March 31 to April 30.

Clinicians eligible for MIPS who have not submitted any MIPS data by April 30 will receive a neutral payment adjustment for the 2021 MIPS payment year.

Hospitals in programs such as the Hospital Inpatient Quality Reporting Program and the Outpatient Quality Reporting Program will not have to submit data to CMS for Jan. 1 through June 30, 2020, as CMS will not count it for performance or payment programs. Deadlines for fourth-quarter 2019 data submissions are optional.

In its announcement, CMS said it recognizes that because of the response to COVID-19, data collected during this time may not reflect the “true level of performance on measures” and that the agency “seeks to hold organizations harmless for not submitting data during this period.”

HRI impact analysis

Industry groups had been pushing for leniency from some requirements as they focus on an all-hands-on-deck response to the COVID-19 pandemic amid many unknowns about how it will affect physicians and hospitals financially.

“Clinicians should be using every tool at their disposal to fight this epidemic; they should not fear having it count against them later,” a coalition of organizations including the American Hospital Association, the American Academy of Family Physicians and the National Association of ACOs wrote in a March 18 letter to CMS Administrator Seema Verma. “They need assurance from the administration that this will not be the case.” 

As Americans are urged to stay home, routine preventive care appointments are delayed and the focus of care centers is on treating rushes of COVID-19 patients, those shifting trends likely will continue to affect an organization’s ability to treat populations in ways that achieve the goals of CMS’ value-based care programs.

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Trine K. Tsouderos

HRI Regulatory Center Leader, PwC US

Tel: +1 (312) 241 3824

Crystal Yednak

Senior Manager, Health Research Institute, PwC US

Erin McCallister

Senior Manager, Health Research Institute, PwC US

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