Quality Payment Program: MIPS Extreme and Uncontrollable Circumstances Policy in Response to COVID-19

April 10, 2020
Policy Snapshot


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The Centers for Medicare & Medicaid Services (CMS) is offering multiple flexibilities to provide relief to clinicians responding to the 2019 Novel Coronavirus (COVID-19) pandemic. In addition to extending the 2019 Merit-based Incentive Payment System (MIPS) data submission deadline to April 30 at 8 PM ET, the MIPS automatic extreme and uncontrollable circumstances policy will apply to MIPS-eligible clinicians who do not submit their MIPS data by the April 30 deadline.

If you are a MIPS-eligible clinician and do not submit any MIPS data by April 30, you will not need to take any additional action to qualify for the automatic extreme and uncontrollable circumstances policy. You will be automatically identified and will receive a neutral payment adjustment for the 2021 MIPS payment year. Note: CMS updated the Participation Status Tool, so you can see if the policy is automatically applied.

CMS also is reopening the MIPS extreme and uncontrollable circumstances application for individuals, groups, and virtual groups. An application submitted by April 30 that cites  COVID-19 will override any previous data submission.

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