On April 20, 2020, the Centers for Medicare & Medicaid Services (CMS) announced that clinicians participating in clinical trials and reporting clinical information related to COVID-19 may now earn credit in the Merit-Based Incentive Payment System (MIPS). CMS stated that this data will be used to drive improvement in patient care and develop best practices to manage the spread of COVID-19.

Physicians, nurse practitioners and others who participate in the Quality Payment Program (QPP) are eligible for credit for the new “MIPS COVID-19 Clinical Trials” improvement activity if they attest that they are participating in a COVID-19 clinical trial that utilizes a drug or biological product to treat COVID-19 patients and that they will report their findings through a clinical repository or clinical data registry for the duration of the study.

MIPS is a performance-based track of QPP that incentivizes quality and value. Performance is measured through data reported in four categories: Quality, Improvement Activities, Promoting Interoperability and Cost. A clinician reporting the new COVID-19 Clinical Trials improvement activity will automatically earn half of the total credit needed to earn a maximum score in the Improvement Activities category, which is worth 15 percent of the clinician’s MIPS final score. 

The new COVID-19 Clinical Trials improvement activity offers flexibility in the type of clinical trial that will qualify. Traditional, double-blind placebo-controlled trials, as well as adaptive or pragmatic designs that flex to workflow and clinical practice, will all qualify. CMS provided the example of reporting through clinical data repositories, such as Oracle’s COVID-19 Therapeutic Learning System, which allows clinicians and patients to record the effectiveness of COVID-19 drug therapies at no cost.

In the release announcing the new improvement activity, CMS Administrator Seema Verma stated that this 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.”

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