Due to the continued effects of the COVID-19 pandemic on the American healthcare system, the Centers for Medicare and Medicaid Services (CMS) announced that it will automatically opt out many MIPS-eligible clinicians from the 2021 performance year.
Don’t worry—we can see your questions from here. The good news is that we’ve got plenty of answers, and we’re fixin’ to share ‘em.
What is MIPS?
The Merit-based Incentive Payment System (a.k.a. MIPS) is a Medicare payment program intended to reward clinicians for improving the quality of their patient care. CMS measures quality in a variety of ways, but participating PTs, OTs, and SLPs must track outcomes measures to help CMS evaluate their patient care and complete improvement activities to help CMS evaluate their clinic processes.
Very few rehab therapists are mandated to participate in MIPS, as the participation threshold only tends to comprise clinicians who work in larger organizations. Still, many therapists who work in smaller clinics have chosen to opt into the program in an effort to secure a piece of the financial incentive pie.
What exactly is CMS doing here?
Back when the MIPS program was first created, CMS created an extreme and uncontrollable circumstances (EUC) policy. This policy allowed MIPS-eligible providers to opt out of the program if they or their practice experienced extreme and uncontrollable circumstances that:
- Prevented them from collecting MIPS data,
- Prevented them from submitting data, and/or
- Affected their normal clinic processes—and therefore their claims data.
In most cases, clinicians had to submit an EUC application to get approval to opt out of the program—though CMS did create an automatic EUC opt out process for clinicians who were affected by natural disasters.
What CMS is doing is essentially extending that policy—specifically that automatic EUC opt out policy—and applying it to most MIPS-eligible clinicians because of the COVID-19 pandemic.
What does this automatic opt out mean for me?
If you are an individual MIPS-eligible clinician who is mandated to report for the program (or if you opted in earlier this year), you are now automatically opted out of the program unless you specifically choose otherwise. This means you:
- Do not have to continue collecting quality measures data;
- Do not have to complete your final improvement activity; and
- Do not have to submit your data for the 2021 performance year.
At the end of the year, you will receive a neutral MIPS score, and you will receive no adjustment—positive or negative—during the 2023 payment year.
Who does this automatic program exception apply to?
This automatic EUC exception applies to all individual MIPS participants. It does not apply to groups, virtual groups, or APM entities.
Do I have to tell CMS that I want to opt out?
Nope. CMS is automatically opting out every individual MIPS participant. If, however, you do not want to be opted out of the program, simply continue collecting data, complete your improvement activities, and submit your data at the end of the year. If you submit data for two categories (i.e., Quality and Improvement Activities), CMS will consider that a signal that you intend to participate in the 2021 performance year.
So if I already submitted data, I’m still participating?
Generally speaking, yes. If you’ve already submitted data for both the Quality and Improvement Activities categories for the 2021 performance year, you are no longer eligible for the automatic opt out. However, you may still manually apply for the extreme and uncontrollable circumstances exemption (which you can do here).
And that about sums up this last-minute legislation from CMS. If you have any more questions about these MIPS flexibilities—or the MIPS program in general—feel free to drop a comment below or reach out to the WebPT Support team. We want to see you succeed, and we’re happy to help!