To further support clinicians during the COVID-19 public health emergency, CMS has extended the deadline for COVID-19 related 2020 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances Exception applications to February 1, 2021.

For the 2020 performance year, CMS will be using the Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, and virtual groups to apply requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency.

If you have any concerns about the effect of the COVID-19 public health emergency on your performance data, including cost measures, for the 2020 performance period, submit an application now and be sure to cite COVID-19 as the reason for your application.

WHAT

The MIPS Extreme and Uncontrollable Circumstances Exception Application allows you to request one or more performance categories be reweighted to 0%.

WHO

Individual Clinicians, Groups, and Virtual Groups

Third Party Intermediaries can apply with permission from the clinician or practice.

• MIPS Alternative Payment Model (APM) Entities can submit an application for 2020.

WHY

You can submit an application to have your MIPS Quality, Cost, Improvement Activities, and/or Promoting Interoperability performance categories reweighted to 0% if:

• You experience an extreme and uncontrollable circumstance outside of your control, such as a natural disaster or public health emergency (PHE) (e.g. COVID-19 pandemic), that prevents you from collecting data for an extended period of time, or that could impact your performance on cost measures.

WHEN

Now through February 1, 2021.  Deadline for CMS to receive 2020 claims for Quality Performance Category: March 1, 2021.  Deadline for Submission: March 31, 2021.

• 2020 MIPS Extreme and Uncontrollable Circumstances Application period closes for COVID-19 related applications only. Clinicians, groups, and virtual groups who believe they are eligible for this exception may apply, and if approved, will qualify for a re-weighting of one or more MIPS performance categories. CMS will notify applicants via email whether their requests are approved or denied. If approved, the exception will be added to the QPP Participation Status Tool.

WHERE

Sign in to qpp.cms.gov with your HCQIS Access and Roles Profile (HARP) account

• For more information about how to create a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide. https://qpp.cms.gov/login.

HOW

1. Register for a HARP account
2. Sign in to qpp.cms.gov
3. Select ‘Exceptions Applications’ on the left-hand navigation
4. Select ‘Add New Exception’
5. Select ‘Extreme and Uncontrollable Circumstances Exception’
6. Complete the application for individual, group, virtual group, or (once available) APM Entity participation

Reference: CMS Exception Application

If you think you might be interested in applying for the MIPS exception and need assistance with the application process, WebsterRogers has a team of dedicated healthcare consultants on standby ready to help.

Contact our Healthcare Services Team for more information or to get assistance: healthcare@websterrogers.com.