The Centers for Medicare & Medicaid Services (CMS) is offering some last-minute reporting relief to practices. CMS has announced that it will automatically apply the extreme and uncontrollable circumstances (EUC) exception for the Merit-based Incentive Payment System (MIPS) 2020 performance year. The agency previously required that practices apply for the exception.
While this is good news (and something the American Academy of Family Physicians advocated for), there are some caveats, and certain MIPS participants will still need to apply for the exception. CMS has therefore reopened the EUC application through 8 p.m. ET on March 31.
Individuals and groups that have not submitted data do not need to do anything. CMS will automatically identify them and they will receive a neutral payment adjustment for the 2022 MIPS payment year. Individuals who have submitted data for only one performance category (e.g., via Medicare Part B claims) will also be automatically identified and receive a neutral payment adjustment. Individuals who have submitted data for two or more performance categories will receive a payment adjustment based on their performance. If you fall into the latter category, you cannot apply to override previously submitted data.
Eligible clinicians who participate in virtual groups must submit an EUC application for all four performance categories (quality, cost, promoting interoperability, and improvement activities) by the March 31 deadline. Groups and virtual groups that have submitted data for a single performance category can apply to have all four categories reweighted. Without an EUC exception, they will be scored in all performance categories unless they are eligible for reweighting in one or more categories. Groups and virtual groups that have submitted data for two or more performance categories will receive a MIPS payment adjustment based on their performance. Again, an EUC application will not override previously submitted data in those cases.
Participants in an Alternative Payment Model (APM) can also submit an EUC application. However, APM Entities must request reweighting for all four categories, and at least 75% of the eligible clinicians within the entity must be eligible for reweighting of the promoting interoperability category. APM Entities may apply for the EUC exception even if they previously submitted data.
Additional information is available on the Quality Payment Program website:
Practices can also contact the QPP help desk Monday through Friday, 8 a.m. to 8 p.m. ET at 866-288-8292.
— Erin Solis, Manager, Practice & Payment, American Academy of Family Physicians
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