CMS Extends Deadline to Apply for MIPS EUC Exception

The extension means that MIPS-eligible individuals, groups, virtual groups and APM entities (i.e., entities that participate in an alternative payment model or similar payer arrangement through a direct agreement with CMS or another payer) have until 8 p.m. ET on March 3 to apply to have their 2022 performance data reweighted due to the COVID-19 public health emergency.

Note that CMS is not applying the automatic MIPS EUC exception policy to individual clinicians for PY 2022; the only way to receive the exception is by applying for it.

MIPS-eligible individuals, groups and virtual groups may apply to reweight any or all MIPS performance categories affected by EUC. APM entities that apply must request reweighting for all performance categories. In addition, at least 75% of MIPS-eligible clinicians in such APM entities need to qualify for reweighting in the Promoting Interoperability performance category.

CMS defines EUC as “rare events entirely outside of your control and the control of the facility in which you practice.” Such circumstances would be expected to

• render participants unable to collect information necessary to submit for a MIPS performance category;
• render participants unable to submit information that would be used to score a MIPS performance category for an extended period of time (e.g. being unable to collect data for the quality performance category for several weeks or months), and/or;
• impact normal processes, affecting participants’ performance on cost measures and other administrative claims measures.

According to a PY 2022 Data Submission FAQs document, EUC applications triggered by the COVID-19 PHE that are received by March 3 and approved will not override data already submitted for individuals, groups and virtual groups. Data submission for an APM entity, on the other hand, will not override performance category reweighting resulting from an approved application.

Download QPP’s COVID-19 Response fact sheet for further details.

Remember, you need a Health Care Quality Information Systems Access Roles and Profile account to submit a MIPS EUC exception application. After you’ve logged in to the QPP website with your HARP credentials, click “Exceptions Application” in the left-hand navigation and then select “Extreme and Uncontrollable Circumstances.” Information on how to obtain a HARP account, as well as how to navigate other aspects of the program, is available in the downloadable QPP Access User Guide.