CMS: Every eligible physician in Georgia will receive at least a neutral MIPS adjustment for 2017 – even if they don’t report  

 

In a presentation that he gave during a ‘MIPS QPP Summit’ in Atlanta on January 25, Richard Wild, M.D. – the chief medical officer for the Centers for Medicare & Medicaid Services Atlanta Region IV – reported that every MIPS-eligible clinician in Georgia will “automatically receive a neutral MIPS payment adjustment, unless you submit data for any of the MIPS performance categories by the submission deadline for 2017” because all 159 counties in the state were declared emergency areas during the hurricanes that took place in 2017.   

Dr. Wild explained that “if you’re located in Federal Emergency Management Agency (FEMA) designated areas affected by Hurricanes Harvey, Irma, Maria or Nate or the California Wildfires, [CMS has] tried to lessen your burden by not requiring you to submit an application to reweight the performance categories…If you’re an affected MIPS eligible clinician, you’ll automatically receive a neutral MIPS payment adjustment, unless you submit data for any of the MIPS performance categories by the submission deadline for 2017, in which case you will be scored on each performance category for which you submit data, according to existing MIPS scoring policies.”

He added that, “This automatic extreme and uncontrollable circumstances policy only applies to you if you’re an individual MIPS eligible clinician in an affected area based on information in the Provider Enrollment, Chain and Ownership System (PECOS).”

Dr. Wild stressed that, “The Extreme and Uncontrollable Circumstances policy does not apply to MIPS eligible clinicians in MIPS Alternative Payment Models (MIPS APMs) in 2017. This is because under the APM scoring standard in the first year of MIPS, an APM entity would normally receive a score that is at least equal to or higher than the performance threshold…”

In terms of the MIPS transition year scoring, Dr. Wild said that, “[CMS] will assign a weight of 0% in the MIPS final score for each performance category where you don’t submit data by the applicable deadline. If you don’t submit any data, you won’t have a negative MIPS payment adjustment for the 2019 MIPS payment year. If you have fewer than 2 performance category scores, you’ll receive a final score that’s equal to the performance threshold and a neutral MIPS payment adjustment. If you’re eligible for reweighting due to extreme and uncontrollable circumstances but still choose to report on two or more performance categories (either as an individual or group), you’ll be scored on those performance categories and your MIPS payment adjustment will be based on your final score.”

CMS notes that the MIPS reporting deadline for the 2017 reporting year is March 31, 2018 – “unless [physicians] report using the web interface, in which case the reporting window ends on March 16, 2018.”      

Go to www.qpp.cms.gov for more information on MIPS/QPP. Contact CMS at 866.288.8292 or QPP@cms.hhs.gov with questions.

Medical Association of Georgia members can also contact Kimberly Ramseur at kramseur@mag.org or 678.303.9274 with questions.

Click for Dr. Wild’s slides

Click for CMS ‘How is 2017 MIPS Participation Determined’ summary