Clinicians to Earn MIPS Credit for Joining COVID-19 Clinical Trial

April 21, 2020 - Clinicians earning value-based reimbursement through the Merit-Based Incentive Payment System (MIPS) will be able to earn credit for participating in and reporting information on COVID-19 clinical trials, according to an announcement from CMS.

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The April 20 announcement stated that CMS recently added the new COVID-19 Clinical Trial improvement activity to MIPS. Eligible clinicians can earn credit for the new improvement activity by attesting that they participate in a COVID-19 clinical trial utilizing a drug or biological product to treat a patient with a COVID-19 infection.

Clinicians must also report their findings through a clinical data repository or clinical data registry for the duration of the study, CMS reported.

“The best scientific and medical minds in the world are working night and day to find treatments to combat Coronavirus,” stated CMS Administrator Seema Verma. “But without solid data, their efforts are liable to run up against a brick wall.”

“At the direction of President Trump, CMS is supporting efforts of researchers to obtain solid, actionable data to accelerate the development of new treatments and our understanding of the coronavirus.  Today’s action encourages clinicians to report data that will help us monitor the spread of the virus, find innovative medical solutions, and unleash scientific discovery as we seek to overcome this terrible disease.”

MIPS is a performance-based track of the Quality Payment Program that incentivizes physicians, physician assistants, nurse practitioners, and other clinicians to deliver quality and value care. Improvement activities is one of four performance categories CMS uses to assess care quality and determine value-based reimbursement.

Eligible clinicians attesting to the new MIPS improvement activity will automatically receive half of the total credits needed to earn a maximum score in the performance category, which counts as 15 percent of final MIPS scores, CMS reported.

The new improvement activity also provides flexibility in the type of COVID-19 clinical trial. For example, CMS will count traditional double-blind placebo-controlled trials to adaptive or pragmatic designs that flexes to workflow and clinical practice, according to the announcement.

COVID-19 clinical trials conducted by the National Institute of Health will satisfy the new MIPS improvement activity criteria, CMS pointed out.

MIPS will also accept data reporting through a clinical data repository like Oracle’s COVID-19 Therapeutic Learning System, which Oracle has developed and donated to a system to the US government. The donated system enables clinicians and patients to record the effectiveness of potential COVID-19 drug therapies at no cost.

Encouraging clinicians to use an open-source data tool to submit COVID-19 clinical trial data will better inform coronavirus research, leading to quicker care improvements, CMS stated.

In light of the recent COVID-19 pandemic, CMS has extended the data submission deadline for MIPS from March 31, 2020, to April 30, 2020, at 8 PM EDT.

CMS will provide scores for individual MIPS eligible clinicians who submit data by April 30 for two or more performance categories. Clinicians will be scored based on those categories and will receive a 2021 MIPS payment adjustment based on their 2019 MIPS final score.

Individual MIPS eligible clinicians who do not submit their data by the new deadline will automatically qualify for the 2019 extreme and uncontrollable circumstances policy, which will not adjust Medicare payments for those who do not submit quality data.

However, the 2019 extreme and uncontrollable circumstances policy does not automatically apply to groups or virtual groups. Groups can apply for the extreme and uncontrollable circumstances policy by April 30, citing COVID-19 as the reason why the group cannot submit quality data to MIPS.