Reminder: MIPS Extreme and Uncontrollable Circumstances Applications due December 31

November 19, 2020
Policy Snapshot

In response to the hardships experienced by clinicians due to the COVID-19 pandemic, the Centers for Medicare and Medicaid Services (CMS) is allowing Merit-based Incentive Payment System (MIPS) eligible clinicians to apply for an exemption for one or more of the MIPS performance categories for Performance Year 2020. This will impact their 2022 MIPS payment adjustments.

With the Extreme and Uncontrollable Circumstances policy, CMS will reweight one or more MIPS performance categories to 0% for approved applicants. Eligible clinicians can submit applications citing COVID-19 as the reason for the requested exemption. Eligible clinicians must submit applications by 8:00 PM ET on December 31, 2020.

Clinicians with approved applications who change their mind and decide to submit data can receive scores for quality, improvement activities, and promoting interoperability performance categories. However, if reweighting of the cost performance category is part of the approved application, the clinician will not be scored on cost measures under any circumstances.

Alternative Payment Model (APM) Entities

In the CY 2021 Medicare Physician Fee Schedule (PFS) proposed rule, CMS proposes to permit Alternative Payment Model (APM) entities to submit applications for the Extreme and Uncontrollable Circumstances policy due to the COVID-19 pandemic to reweight MIPS performance categories. APM entities will have all performance categories reweighted, regardless of data submission, with an approved application.

CMS clarifies that they are allowing APM entities to submit applications now through December 31, 2020. CMS will not be able to make final determinations on applications unless the policy proposal is finalized in the CY 2021 PFS final rule (expected to be released on or around December 1, 2020). If the policy is finalized and an APM Entity’s application is approved, MIPS-eligible clinicians in the APM Entity group would receive a neutral payment adjustment (0%) in 2022.

Additional information on the COVID-19 opt out option for the 2020 MIPS performance year is available on the 2020 Exceptions Applications Fact Sheet, and in the 2021 QPP Proposed Rule Fact Sheet.

Tax terms: CMS, QPP. Payments, Practice Management, Practitioners