Merit-Based Incentive Payment System
- 2020 Reporting Exemptions Due to COVID-19: CMS is granting hardship exemptions to Merit-Based Incentive Payment System (MIPS) reporting requirements on a case-by-case basis due to COVID-19. It is therefore possible for a clinician or group to request exemption from all four performance categories in 2020 (see Table 2). If clinicians submit a hardship exception application for all four MIPS performance categories and their application is approved, they will be held harmless from a payment adjustment in 2022—meaning they will not be eligible for a bonus and not face potential penalties based on their MIPS performance in 2020.
- Performance Threshold: CMS proposes to set the performance threshold that clinicians need to achieve to avoid a penalty in 2021 at 50 points, down from 60 points, which had been floated previously.
- MIPS Value Pathways (MVPs): CMS is committed to developing MVPs, which would combine all four categories of MIPS reporting into a single, more harmonized process. However, due to COVID-19, the implementation of MVPS is being delayed until 2022. ACEP is working with CMS on developing an MVP for emergency medicine and is examining how ACEP’s qualified clinical data registry, the Clinical Emergency Data Registry (CEDR), can help emergency physicians participate in an MVP.
Additional information on MIPS is available here.
Explore This IssueACEP Now: Vol 39 – No 09 – September 2020
Resources for these and other topics can be found on the reimbursement section of the ACEP website. ACEP Director of Reimbursement David McKenzie, CAE, is also available to field your questions at 800-708-1822, ext. 3233. Finally, ACEP offers well-attended and highly recommended coding and reimbursement educational conferences annually. Visit www.acep.org/rc for more information.
Dr. Granovsky is president of LogixHealth, an ED coding and billing company, and currently serves as the course director of ACEP’s Coding and Reimbursement courses. He may be reached at email@example.com.
Mr. McKenzie is ACEP director of reimbursement.
Advocate to Waive Budget Neutrality
Efforts are under way to ask Congress to waive budget neutrality for 2021 and maintain the Medicare payment per RVU close to current levels.
A more detailed fact sheet on the 2021 PFS payment proposals can be found here.
Also, check out a blog from Jeff Davis, ACEP’s director of regulatory affairs, that highlights key proposals in the rule here.
Less than 20 hours after CMS released the proposed rule, ACEP sent a letter to Congress expressing our strong concerns on this proposed cut, noting the unprecedented strain emergency physician practices already are facing due to the ongoing COVID-19 pandemic.
Congress has the power to fix this by waiving the budget neutrality requirement. If Congress acts, emergency medicine reimbursement could actually increase by about 3 percent instead of decreasing by 6 percent.
What can you do?
Urge your member of Congress to waive the budget neutrality requirement for calendar years 2021 and 2022 here.
Congress is already juggling many other priorities as a result of the pandemic and pressure from the upcoming November elections. It is essential that they hear directly from emergency physicians in their district just how devastating these cuts could be for access to emergency care for patients across the country.