Reminder: 2020 MIPS Extreme and Uncontrollable Circumstances Exception Application Deadline for COVID-19 has been Extended to February 1, 2021

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 submit an application 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.

If you have an approved application, you can still receive scores for the Quality, Improvement Activities and Promoting Interoperability performance categories if you submit data. If the cost performance category is included in your approved application, you will not be scored on cost measures even if other data are submitted. IMPORTANT: Individuals, groups, and virtual groups can’t submit an application to override PY2020 data that has already been submitted. Any data submitted as an individual, group, or virtual group before or after an application has been approved will be scored. Learn more in the 2020 Exceptions Applications Fact Sheet. 

Note: The deadline to submit a MIPS Promoting Interoperability Performance Category Hardship Exception application or an Extreme and Uncontrollable Circumstances application not related to COVID-19 will remain December 31, 2020. Remember, if you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply.

How do I Apply?

You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself, or another MIPS eligible clinician, group, virtual group or APM Entity. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you register for a HARP account, sign in to qpp.cms.gov, select “Exceptions Applications” on the left-hand navigation, select “Add New Exception,” and select “Extreme and Uncontrollable Circumstances Exception” or “Promoting Interoperability Hardship Exception.”

How do I Know if I’m Approved?

If you submit an application for either of the exceptions, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but may not appear in the tool until the submission window is open in 2021.

For APM Entities Only

In the 2021 Medicare Physician Fee Schedule (PFS) Final Rule, CMS has finalized its previous proposal to allow Alternative Payment Model (APM) Entities to submit an application to reweight Merit-based Incentive Payment System (MIPS) performance categories as a result of extreme and uncontrollable circumstances. In addition, CMS has extended the application deadline to February 1, 2021.

If an APM entity’s application is approved, that APM entity will receive a final score equal to the performance threshold for the 2020 MIPS performance year, and the MIPS eligible clinicians in the APM entity group would receive a neutral payment adjustment in 2022.

Who is Eligible to Submit an Application?

APM entities affected by extreme and uncontrollable circumstances in the following models are able to submit an application:

• Medicare Shared Saving Program (SSP)
• Next Generation ACO Model
• Vermont Medicare ACO Model
• Comprehensive Primary Care Plus (CPC+)
• Comprehensive ESRD Care (CEC)
• Bundled Payments for Care Improvement (BPCI)
• Oncology Care Model (OCM)
• Maryland Primary Care Program
• Independence at Home Demonstration

What are the Application Requirements?

Unlike those that choose to apply as individual clinicians, groups, or virtual groups, APM entities must apply to reweight all MIPS performance categories to 0%. Additionally, 75% of the MIPS eligible clinicians in the APM entity must qualify for reweighting in the MIPS Promoting Interoperability performance category. They may qualify automatically or through a MIPS Promoting Interoperability Hardship Exception Application (due December 31, 2020).

CMS does not require APM Entities to submit documentation with their applications. However, APM entities should retain documentation of the circumstances supporting their application for their own records in the event they are selected by CMS for data validation or an audit.

Will Submitting Data Void the Exception?

Data submitted for an APM entity will not override performance category reweighting from an approved application. This differs from the policy for individual, group, and virtual group applications.

Will an Approved Application Affect Model-Specific Reporting Requirements?

If an APM entity’s application is approved, the approval would only affect MIPS reporting, and that APM entity would still be required to meet its model-specific reporting requirements.

For more information:

• View this video and guide that walk you through how to submit the application
• Visit the Extreme and Uncontrollable Circumstances Exception QPP webpage for more information and link to the application
• Check out the Exceptions Application Fact Sheet to learn more about these exceptions.

Questions?

Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 AM and after 2:00 PM ET. Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.