Physicians who are participating in the Merit-Based Incentive Payment System (MIPS) should take note of these important deadlines recently published by the Centers for Medicare and Medicaid Services (CMS):

December 31, 2020

• 2020 Promoting Interoperability Hardship Exception Application period closes. Clinicians, groups and virtual groups who believe they are eligible for this exception may apply, and if approved, will qualify for a re-weighting of the MIPS Promoting Interoperability performance category.
   
• 2020 Extreme and Uncontrollable Circumstances Application period closes for all reasons not related to COVID-19. CMS will notify applicants via email whether their requests are approved or denied. If approved, the exception will also be added to the QPP Participation Status Tool (however, it may not appear in the tool until the submission window opens in 2021).
   
• 2021 virtual group election period closes. Solo practitioners and groups with 10 or fewer clinicians (including at least one MIPS eligible clinician) who want to participate in MIPS as a virtual group for the 2021 performance year must submit their election to CMS by this date.

January 4, 2021

• 2020 MIPS performance year data submission window opens.

February 1, 2021

• 2020 Extreme and Uncontrollable Circumstances Application period closes for COVID-19 only. Clinicians, groups, and virtual groups who believe they are eligible for this exception may apply, and if approved, will qualify for a re-weighting of one or more MIPS performance categories. CMS has finalized that for the 2020 performance year, Alternative Payment Model (APM) Entities may submit Extreme and Uncontrollable Circumstances applications as a result of COVID-19. For more information about the impact of COVID-19 on Quality Payment Program participation, see the Quality Payment Program COVID-19 Response webpage.

March 1, 2021

• Deadline for CMS to receive 2020 claims 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 administrative contractor. Check with each contractor for specific instructions (click here for the list of California contractors).   

March 31, 2021

• 2020 MIPS performance year data submission window closes.

To learn more, visit the Quality Payment Program (QPP) website and access the following resources:

• 2021 Virtual Group Toolkit
• About QPP Exceptions Webpage
• 2020 MIPS Exceptions Application Fact Sheet
• 2020 MIPS Extreme and Uncontrollable Circumstances Application Resources

For questions, contact QPP at (866) 288-8292 or QPP@cms.hhs.gov.