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Hold Harmless: MIPS Cost Category

On May 20, 2021, the Centers for Medicare & Medicaid Services announced that the hotly debated cost category will be reweighted to 0% for 2020, effectively eliminating it from scoring as part of the Merit-based Incentive Payment System (MIPS). Advocates for physicians – including the American Medical Association – had advocated for the reweighting based on the impact of the COVID-19 pandemic. This announcement only applies to those physicians who participated in the program. Many physicians did not report to the program in 2020, which will not impose the expected penalties in 2022 for non-participation based on the pandemic. 

The 2021 exception applications are now open, should you wish to take steps to eliminate your participation (and any penalty) this year. Because the pandemic is considered an “extreme and uncontrollable circumstance,” any physician can apply for the exception. Should you change your mind, the program will set aside the exception application, so it makes for a great back-up plan. The penalty is a substantial 9% (applied to all Medicare payments) for non-participants in perpetuity, so it should be on your calendar to participate each year – or submit that application.

About The Author

Elizabeth Woodcock is the founder and principal of Woodcock & Associates. She has focused on medical practice operations and revenue cycle management for more than 25 years. She has led educational sessions for a multitude of national professional associations and specialty societies, and consulted for clients as diverse as a solo orthopaedic surgeon in rural Georgia to the Mayo Clinic. She is author or co-author of 17 best-selling practice management books, to include Mastering Patient Flow and The Physician Billing Process: Avoiding Potholes in the Road to Getting Paid. Elizabeth is a Fellow in the American College of Medical Practice Executives and a Certified Professional Coder. In addition to a Bachelor of Arts from Duke University, she completed a Master of Business Administration in healthcare management from The Wharton School of Business of the University of Pennsylvania. She is currently a doctoral student at the Bloomberg School of Public Health of Johns Hopkins University.

The contents of The Sentinel are intended for educational/informational purposes only and do not constitute legal advice. Policyholders are urged to consult with their personal attorney for legal advice, as specific legal requirements may vary from state to state and/or change over time.

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