| Those of you who read my emails and attend or watch/listen later to my webinars (now available on the SoundCloud App so there is no need to be confined to a screen as you learn about relevant practice management and planning for the future) are aware of my feelings about MIPS…If I were a physician I would not participate.
As you know for the past several years, practices have been able to claim a hardship exception (meaning no “bonus” and no “ding”) due to “Extreme and Uncontrollable Circumstances” brough on by COVID. Well, that was good while it lasted (not COVID, the exception) but as of May 2023, the government declared the public health emergency “over.” This year in February a new set of “Extreme and Uncontrollable Circumstances” began leaving many practices with little to no cash flow for months…The Change Healthcare cyberattack!
In case you missed the APMA’s announcement way back in May (and since it’s the time of year that I start receiving lots of reporting questions) it said:
“APMA and others requested that CMS allow providers impacted by the Change Healthcare cyberattack to apply for a hardship exception from MIPS participation in 2024.” This request has been granted!
You have until 8:00 p.m. EST on December 31, 2024 to apply (use the link and instructions below) if your practice was affected in a way (most were in some way).
Complete the application online
Choose “Ransom/Malware” as the “Event Type”
Confirm in the application that the ransom/malware event pertained to the “Change Healthcare cyberattack”
Write a little blurb about how this event caused you to commit additional staff, time and resources to assist with revenue cycle tasks (which allow you to keep your doors open and treat patients). Thus, allocating time to collecting and reporting MIPS information was not feasible for several months.
Updated CLARIFICATION:
As was brought to my attention by Michael Brody, DPM of TLD Systems following my email, according to CMS:
“Any clinician, group, subgroup, virtual group, or APM Entity that wasn’t able to submit their MIPS data solely because of the Change Healthcare cyberattack can request reweighting.”
My previous email on the subject stated that most practices were affected in some way by the cyberattack so claiming the hardship exception was an option for you. As we all know, decreases in reimbursement and payers that are slow to pay negatively impact practices enough already without the additional strain of claims stuck in limbo due to this attack, but please use your best judgement to decide if this is an appropriate reason to apply before doing so.
The full text of the CMS statement can be found in the link below.
https://www.aafp.org/pubs/fpm/blogs/gettingpaid/entry/mips-data-cyberattack.html |
