CMS announced on Monday, April 20, 2020, that healthcare providers will be able to accumulate credit in the Merit-Based Incentive Payment System (“MIPS”) when participating in clinical trials involving COVID-19 and when reporting COVID-19 clinical data. This incentive arises as a result of CMS adding the new COVID-19 Clinical Trial Improvement Activity to MIPS in an effort to accumulate vital data regarding patient care. The aim is to develop innovative best practices in order to monitor and combat the spread of COVID-19.
According to the April 20, 2020 announcement, eligible clinicians who receive reimbursement through the Quality Payment Program (“QPP”) and choose to participate and report data from COVID-19 clinical trials will be eligible to earn credit through value-based reimbursement in MIPS. Eligible clinicians include but are not limited to: physicians, physician-assistants, and nurse practitioners.
MIPS COVID-19 Clinical Trials Improvement Activity Credit Requirements:
In order to receive MIPS COVID-19 credit, clinicians must:
- Attest to participating in COVID-19 clinical trials;
- Utilize a drug or biological product in the trial to treat a patient with COVID-19; and
- Report their findings through a clinical data repository or clinical data registry for the duration of their study.
The announcement confers wide latitude to the types of clinical trials eligible, all of which constitute “new improvement activity” for reimbursement purposes. For example, creditable clinical trials may include trials conducted by the National Institute of Health or the “traditional double-blind placebo-controlled trial to an adaptive or pragmatic design that flexes to workflow and clinical practice.”
This flexibility for eligible clinical trials related to COVID-19 greatly influences scoring. CMS acknowledged the implications of this broad flexibility, stating that “clinicians who report these activities will automatically earn half of the total credit needed to earn a maximum score in the MIPS improvement activities performance category, which counts as 15% of the MIPS final score.”
Advis will continue to track these developments. Advis will provide further guidance if these clinical trial updates are included in subsequent legislation.
Please refer to our COVID-19 Information Repository for Advis’s previous updates and recommendations for ensuring program compliance throughout the pandemic.
If you need assistance preparing data requests, or to discuss emerging issues with MIPS credit for clinicians, Advis is available daily and throughout the weekend. Please contact us or email one of our experts. We will respond as soon as possible. Don’t forget to subscribe to our digital mailing list for regulatory updates.
Published: April 22, 2020
