The Centers for Medicare and Medicaid Services (CMS) have opened hardship applications for the 2021 MIPS performance year, extending the option for participants to claim the Extreme and Uncontrollable Circumstances (EUC) Exception due to COVID-19 for second year.

MIPS eligible clinicians, groups, virtual groups, and MIPS APM participants can apply to reweight any or all MIPS performance categories in the event an EUC resulted in the following:

  • You were unable to collect information necessary to submit for a MIPS performance category;
  • You were unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for 3 months), and/or;
  • Your normal process was impacted, affecting your performance on cost measures and other administrative claims measures.

To receive a final score and payment adjustment under the MIPS program, a participant must be scored on at least two of the four performance categories.  Those requesting reweighting through the hardship application will receive a neutral score with no payment adjustment for the 2023 payout year.

After an application is approved, submitting data on a performance category will override the applicant and a participant will be scored on their submission. Applications can also be withdrawn through the Quality Payment Program website.

As MIPS is a budget neutral program, bonus payment adjustments are directly related to the number of penalties being collected. The impact of the EUC applications on the 2020 performance year is still unknown until final scores and payment adjustments are released this summer.

Those interested must submit their applications to CMS through their QPP account by December 31, 2021.

For CMS’s guide on the Extreme and Uncontrollable Circumstances application, CLICK HERE.

As always, ADVOCATE will continue to keep you informed on the issues impacting medical groups as they develop.

Kayley Jaquet

Manager, Regulatory Affairs