Medicare Advocacy

Physician Payment Reform

The passage of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repealed the Sustainable Growth Rate (SGR) and replaced it with two new payment update tracks, the Merit-based Incentive Payment System (MIPS) and CMS Alternative Payment Models (APMs). Payment adjustments under the MIPS and APM programs went into effect January 1, 2019.

To further support clinicians during the COVID-19 public health emergency, the Centers for Medicare & Medicaid Services (CMS) is extending the 2020 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances Exception application deadline to February 1, 2021. For more information please click here.

Clinicians will be notified by CMS via email if their exception request was approved or denied. If approved, the exception will be added to the QPP Participation Status Tool, but may not appear in the lookup tool until the submission window opens in 2021.

2020 Quality Payment Program Exception Applications Fact Sheet

January 4, 2021: CMS opens window for submitting MIPS data for the 2020 MIPS performance year.

March 1, 2021: Deadline for CMS to receive 2020 claims data for the Quality performance category. Claims must be received by CMS within 60 days of the end of the performance period. Deadline dates vary to submit claims to the MACs. Check with your local MAC for more specific instructions.

March 31, 2021: CMS closes window for submitting MIPS data for the 2020 MIPS performance year.

Please note that the dates provided are only for the CMS QPP interface. Clinicians reporting via the Reg-ent registry, or through another MIPS reporting tool, should be aware that each vendor maintains its own timeline for submissions. Clinicians should contact their reporting vendor for details; Reg-ent participations should email [email protected].

On June 24, the Centers for Medicare & Medicaid Services announced that because of the COVID-19 pandemic, additional flexibilities are available to clinicians participating in the Quality Payment Program Merit-based Incentive Payment System (MIPS). Clinicians significantly impacted by the public health emergency may submit an Extreme & Uncontrollable Circumstances Application to reweight any or all of the MIPS performance categories for performance year 2020. To be considered for this exemption, providers must submit their application before December 31.

Access the QPP COVID-19 Response Fact Sheet

The 2019 data submission deadline has been extended by 30 days, from March 31, 2020, to April 30, 2020. If clinicians have already submitted MIPS data, or if they choose to submit MIPS data by April 30, 2020, they will be scored and receive a MIPS payment adjustment based on the data submitted. If clinicians need to revise any data that has already been submitted, changes can still be made by logging into by April 30, 2020.

  • MIPS eligible clinicians who have not submitted any MIPS data by April 30, 2020, do not need to take any additional action to qualify for the automatic extreme and uncontrollable circumstances policy. These clinicians will be automatically identified and receive a neutral payment adjustment for the 2021 MIPS payment year.
  • All four MIPS performance categories for these clinicians will be weighted at zero percent, resulting in a score equal to the performance threshold, and a neutral MIPS payment adjustment for the 2021 MIPS payment year. However, if a MIPS eligible clinician submits data on two or more MIPS performance categories, they will be scored and receive a 2021 MIPS payment adjustment based on their 2019 MIPS final score.

CMS recognizes that quality measure reporting may not be reflective of performance for measures such as cost, readmissions, and patient experience during this time of emergency. As such, the agency seeks to hold organizations harmless for data during this period. CMS will continue to monitor the situation and adjust reporting periods and submission deadlines accordingly. More detailed information about changes to each of these quality reporting programs will be provided as it becomes available.

For members reporting MIPS 2019 through the Reg-ent registry, please see specific guidance below:

  • Ready to submit? If you and your practice are ready to submit your data to CMS, we encourage you do this by the March 31, 2020 deadline.
  • Not yet ready to submit? If you require additional time to prepare your submission, please take advantage of the extra time provided by CMS with this deadline extension. However, it is essential that you continue to work with the FIGmd Client Account Support (CAS) to complete your submission prior to the extended deadline of April 30, 2020.
  • Already submitted? If you are satisfied with your submission, there is no need to resubmit due to the deadline extension. However, if you would like to resubmit your data for any reason, please contact the Reg-ent team for assistance.

The Reg-ent team is committed to supporting our members with their MIPS 2019 reporting. We ask that you continue to meet with the FIGmd Client Account Support team as scheduled over the coming weeks to ensure that you complete your submission to CMS as soon as possible. We recognize the challenges being faced by our members and their practices and want you to know that we are here to help you to successfully submit.

Please contact the Reg-ent teams at [email protected] and [email protected] for more information, for assistance with your submission, or with any questions. Please remember to include your practice name and Reg-ent Practice ID to facilitate a timely response.

Clinicians can use the updated CMS Quality Payment Program Status Lookup Tool to check initial 2020 eligibility for the MIPS program. By entering a National Provider Identifier in the lookup tool, providers can determine eligibility for the 2020 performance period. Eligibility does change during the second half of the year, so it is recommended that clinicians check their status throughout the year. Final eligibility will be available by December 2020.

Performance Threshold

The Merit-based Incentive Payment System is raising the performance threshold points from 30 in 2019, to 45 in 2020. This significant jump will make avoiding a negative payment adjustment more difficult.

  • As required by MACRA, the 2020 performance may result in a Medicare payment adjustment of up to +/- 9% in 2022.
  • The exceptional performance threshold will be raised to 85 points.
  • CMS maintained the performance category weights from 2019 for 2020:
    • Quality: 45%
    • Cost: 15%
    • Improvement Activities: 15%
    • Promoting Operability: 25%

Quality Category

Important changes have been made in the Quality category.


  • For 2020, CMS increased the data completeness threshold for this category by 10 percentage points. Clinicians will now need to report each measure for at least 70% of applicable patients (up from 60% in 2019).
  • CMS removed 42 quality measures and added six new specialty-measure sets, including those for endocrinology and pulmonology.



In the Cost category, 10 new episode-based measure have been added so that more providers will qualify for this category. Also, CMS is revising the Medicare Spending Per Beneficiary Clinician and Total Per Capita Cost measures.

  • CMS kept the weighting of the Cost category at 15%. However, clinicians can expect an increase in the Cost category weight in MIPS year five.
  • CMS will maintain the existing 8 episode-based measures and add 10 new episode-based measures for a total of 18 episode-based Cost measures.

Improvement Activities Category

  • Starting in 2020, groups can only attest to Improvement Activities if at least 50% of the clinicians in the group or virtual group complete the same activity during any continuous 90-day period. Previously, at least one clinician in the group needed to complete the activity for the group to receive credit.
  • The activities may be completed anytime within the calendar year.
  • CMS added two new Improvement Activities measures, modified seven existing measures, and removed 15 measures.

Promoting Interoperability Category

  • CMS reduced the threshold for a group to meet the definition of hospital-based and qualify for reweighting of the PI component. In 2019, in order to reweight the PI component, 100% of clinicians in a group had to meet the CMS definition of a hospital-based clinician. In 2020, more than 75% of clinicians in a group must meet the definition of hospital-based, in order for the group to have the category reweighted for the 2020 performance year / 2022 payment year.

For more information and resources, visit the CMS Quality Payment Program Resource Library

For questions regarding 2020 final requirements, contact the Health Policy team at [email protected]

CMS implemented extensive updates for the third year of the Merit-based Incentive Payment System (MIPS). Key programmatic changes for 2019 address eligible clinicians, technology requirements, performance categories, scoring methodology, measures and objectives, as well as thresholds and bonus points. The items below highlight some of the major changes for Year 3 (Y3) that AAO-HNS members need to know:

  1. More MIPS eligible clinicians – Eligible Clinicians (ECs) represent the same five provider groups from Y2, but now also include additional practitioners such as qualified audiologists, clinical physical therapists, occupational therapists, qualified speech-language pathologists, and registered dieticians or nutrition professionals.
  2. 2015 Certified Electronic Health Records Technology (CEHRT) required – Submission of data in each of the following performance categories now requires 2015 CEHRT: Quality, Improvement Activities, and Promoting Interoperability.
  3. Modified performance category weights – The weighting of the Quality category decreased from 50 percent to 45 percent of the final MIPS score. while the Cost category increased to 15 percent. Promoting Interoperability and Improvement Activities categories remain the same (25 percent and 15 percent, respectively).
  4. Restructured Promoting Interoperability performance category – This performance category includes the following new element
    • Base, performance, and bonus scores were eliminated and replaced with a new scoring methodology (100 total category points)
    • Two new e-prescribing objectives are available; and
    • ECs must meet four objectives: e-prescribing, health information exchange, provider to patient exchange, and public health and clinical data exchange, unless an exclusion is granted. ECs are also required to report certain measures associated with the objectives.
  5. New Quality measures – CMS added eight new quality measures for 2019 and removed 26 measures that were duplicative or “topped out.”
  6. Increased thresholds to avoid penalties and obtain bonus points – ECs and groups must earn at least 30 points (an increase from the 15 points required in 2018) to ensure a neutral payment adjustment. ECs and groups seeking a performance bonus must also earn at least 75 MIPs points (an increase from 70 points in 2018).
  7. Modified small practice point system – Small practices (<15) will still receive a small practice bonus, but for 2019, the bonus is now reflected in the Quality performance category score instead of a standalone bonus. If ECs submit data on at least one Quality measure, the bonus points will be increased to six points (as compared to five points in 2018).
  8. MIPS Opt-In policy – ECs or groups may opt-in to MIPs if they exceed at least one, but not all three, of the low-volume threshold criteria.
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