Published March 23, 2020

CMS Provides Broad Relief Under Quality Reporting Programs

On March 22, the Centers for Medicare & Medicaid Services (CMS) announced broad relief for providers under the agency’s multiple quality reporting programs. This includes: (1) giving providers the option to forgo 2019 reporting requirements, and (2) excluding data (and thus eliminating reporting requirements) for the period January 1, 2020, to June 30, 2020, for several (but not all) programs.

Merit-Based Incentive Payment System (MIPS) eligible clinicians were facing a March 31 deadline for submitting 2019 performance data. That deadline now has been extended to April 30, 2020. Providers that elect not to report any data by the April 30 deadline will qualify for the automatic extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year.

Regarding the 2020 MIPS performance year, CMS is evaluating options for providing relief around participation and data submission.

The agency offered the same comment for the Medicare Shared Savings Program. Participating accountable care organizations (ACOs) have expressed significant concern, arguing that COVID-19-related costs will eliminate any chance to earn shared savings and expose those ACOs with downside risk to significant losses.

For all hospital quality reporting programs, CMS is affording hospitals the opportunity to forgo submitting data for Q4 2019 (October 1 to December 31). If a hospital elects to submit the data, it will be used to calculate the 2019 performance and payment (where appropriate). Otherwise, 2019 performance will be calculated based on data from January 1 to September 30.

For 2020, CMS will not count data from January 1 to June 30 for any hospital performance or payment programs. Hospitals do not need to submit data to CMS for this time period. CMS notes that if a hospital submits data for Q1 for the Hospital-Acquired Condition Reduction Program and/or the Hospital Value-Based Purchasing Program, it will be used for scoring in the program, where appropriate.

For post-acute care providers (the home health, hospice, inpatient rehab, long-term care hospital [LTCH], and skilled nursing facility [SNF] quality reporting programs, and the SNF value-based purchasing program), CMS is applying the same rules as the hospital programs.

Also, CMS will not require submission of Home Health and Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey data from January 1, 2020, through September 30, 2020.  Finally, CMS notes that for the SNF Value-Based Purchasing Program, qualifying claims will be excluded from the claims-based SNF 30-Day All-Cause Readmission Measure calculation for Q1 and Q2 2020.

If you have any questions related to this latest CMS guidance about quality reporting programs, or would like assistance with any matter related to value-based care, reimbursement, strategy and integration, compliance, or valuation, contact one of our PYA executives below at (800) 270-9629.

Disclaimer: To the best of our knowledge, this information was correct at the time of publication. Given the fluid situation, and with rapidly changing new guidance issued daily, be aware that some or all of this information may no longer apply. Please visit our COVID-19 hub frequently for the latest updates, as we are working diligently to put forth the most relevant helpful guidance as it becomes available.

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