CMS reopens MIPS exception applications for practices hit by Change Healthcare cyberattack

Practices affected by the Change Healthcare cyberattack have until 8 p.m. ET Oct. 11 to apply for reporting relief for the Merit-based Incentive Payment System (MIPS) 2023 reporting year. The Centers for Medicare & Medicaid Services (CMS) reopened the extreme and uncontrollable circumstances (EUC) application window for MIPS physicians, groups, and alternative payment model (APM) entities who were unable to submit data because of the cyberattack. (The previous deadline was April 15). CMS will only approve applications citing the cyberattack as the basis for requesting the reweighting of performance categories.

Participants must submit applications through the MIPS Targeted Review form on the Quality Payment Program (QPP) website. This is different than the MIPS EUC Exception Application, which is now for the 2024 performance year only and should not be used to request reweighting due to the Change Healthcare cyberattack. The 2023 MIPS EUC Reweighting Requests Guide provides step-by-step instructions.

Applications will not override previously submitted data, but practices impacted by the cyberattack that already submitted data could still consider submitting a reweighting application for the cost category, because that one does not require data submission. Consistent with their established reweighting policies, CMS will calculate a final score for eligible clinicians who are scored on two or more performance categories. Those scored on fewer than two categories will default to a final score equal to the performance threshold.

Below are some additional important deadlines:

• 2023 Targeted Review Request (8 p.m. ET Oct. 11)
• 2024 MIPS Value Pathway Registration (Dec. 2)
• 2024 MIPS EUC Exception (8 p.m. ET Dec. 31)

— Erin Solis, Manager, Practice & Payment at the American Academy of Family Physicians

Posted on Sept. 27, 2024