MIPS Extreme and Uncontrollable Circumstances Application Reopens

Mar 23, 2022

CMS has reopened the 2021 MIPS EUC application to allow groups, virtual groups, and APM Entities to submit an application requesting MIPS performance category reweighting due to the ongoing COVID-19 PHE. (Because of the automatic EUC policy, individual clinicians don’t need to submit an application.)

MIPS EUC applications citing COVID-19 as the triggering event can be submitted until Thursday, March 31, 2022, at 8 p.m. ET. Apply Now. You need an HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application.  Refer to the Register for a HARP Account document in the QPP Access User Guide for more information on HARP accounts QPP Access User Guide

Deadline Extended to March 31, 2022

Groups and Virtual Groups

Groups and virtual groups can’t apply to override data that has already been submitted. 

Any data submitted for a group or virtual group (before or after an application has been approved) will be scored.

  • If only one performance category can be scored (meaning the other three performance categories are weighted at 0%), the group or virtual group will receive a final score equal to the performance threshold. 
  • The MIPS eligible clinicians in the group will receive a neutral payment adjustment unless they have a higher score from individual or APM Entity participation. MIPS eligible clinicians participating as a virtual group always receive the virtual group’s score.

Example: A small practice reported Medicare Part B claims measures throughout the performance year and automatically received a group-level quality score based on these measures. The practice submits a group-level EUC application citing COVID-19, and the group is approved for reweighting all performance categories.

  • As long as no additional data is submitted at the group level (or available for scoring, such as the automatic improvement activities credit awarded to groups with clinicians participating in an APM), the improvement activities, Promoting Interoperability and cost performance categories will be weighted at 0%.
     
  • We’ll still score the group on their reported Medicare Part B claims measures, but the quality performance category will be weighted at 100% of the group’s MIPS final score.
     
  • As a result, the group will receive a final score equal to the performance threshold, and all MIPS eligible clinicians in the group will receive a neutral payment adjustment unless they have a higher score from individual or APM Entity participation.

For more information on this application, please refer to the 2021 MIPS Extreme and Uncontrollable Circumstances Application Guide (PDF).