The Centers for Medicare & Medicaid Services (CMS) shared additional clarity around the Extreme and Uncontrollable Circumstances Exception due to 2019 Novel Coronavirus (COVID-19) for Performance Year 2020.
Who can apply?
Merit-based Incentive Payment System (MIPS) eligible clinicians, groups, and virtual groups may submit an application for re-weighting of any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances that impact these categories.
Extreme and uncontrollable circumstances are defined as rare events entirely outside of your control and the control of the facility in which you practice.
These circumstances would:
- Cause you to be unable to collect information necessary to submit for a MIPS performance category;
- Cause you to be 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;
- Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.
If you believe you have been affected by an extreme and uncontrollable circumstance (such as the public health emergency triggered by the COVID-19 pandemic) as outlined above, you can apply for this exception.
MIPS Eligible Practices
Any MIPS-eligible practice that does not participate in an APM may request an extreme hardship exemption from reporting any or all MIPS categories (Quality, Improvement Activities, Promoting Interoperability, and/or Cost). An exception to all categories results in an exclusion from MIPS reporting for performance year 2020 and a neutral payment adjustment in 2022. If a practice reports on two or more categories (excluding cost), then the exception will be revoked. Practices reporting Quality Measures through claims will retain their exception if they do not report for Improvement Activities or Promoting Interoperability
MIPS Advanced Payment Model (APM) Participants
CMS has proposed an expansion of this exception to include MIPS APMs, such as an Accountable Care Organization (ACO) or Medicare Shared Saving Program (MSSP) entity. While individual practices cannot receive an exemption for themselves, an APM may apply for an exception that covers the APM as a whole. If you would like to understand how these proposals may impact your practice, then we recommend contacting your APM. Our QPP/MIPS experts are available to provide further explanation or assistance if needed.
How do I apply?
Beginning with PY 2020, you will need a HCQIS Access Roles and Profile (HARP) account to submit an Extreme and Uncontrollable Circumstances Application.
- Sign into QPP Portal with your credentials
- Click ‘Exceptions Application’ on the left-hand navigation
- Select ‘Extreme and Uncontrollable Circumstances’
For more information on how to obtain a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide.
The Extreme and Uncontrollable Circumstances Application for PY 2020 is currently open and will close December 31, 2020.
What information do I need to include?
Applicants must demonstrate that COVID-19 has prevented a practice from collecting data for an extended period of time or has impacted the practice’s performance on cost measures. While practices are not required to submit documentation with the application, they should retain documentation of their circumstances supporting their application for their own records in the event they are selected by CMS for data validation or audit.
Actions that may quicken the approval process or reduce the likelihood of requests for additional information include the following:
- Enter the dates during Performance Year 2020 that your practice’s ability to collect data and your performance within MIPS categories have been impacted. If your practice has regained these capabilities, then enter the date that occurred. Otherwise, check on-going.
- Check off the specific MIPS categories for which you are requesting an exception; for a full program exception check off all four MIPS categories on the application even if you submit quality data on claims.
- In the narrative section of the application, identify the specific reporting categories that you are requesting an exemption. Simply checking off the categories on the application may not be sufficient.
- Clarify how COVID-19 has impacted your ability to collect data for quality measures, improvement activities, and/or Promoting Interoperability reporting and to manage costs for Medicare services. Impacts your practice could consider identifying include the following:
- a significant reduction in the number of Medicare patients served
- an extended period of practice closure
- disruptions to staffing or work processes (especially those involved in performing activities, recording information, or reporting data related to MIPS)
- a delay or inability to implement cost-saving or quality improvement initiatives
- To the extent possible, explain the COVID-19 impacts on each of the MIPS categories that you are requesting an exception. Stating that COVID-19 has impacted your overall MIPS capabilities without tying those impacts to the specific category may not be sufficient.
How do I know if my application is approved
You’ll be notified by email if your request was approved or denied. You will also be able to check the status of your application by signing into QPP Portal. If approved, this will also be added to your eligibility profile in the QPP Participation Status Tool, but may not appear in the lookup tool until the submission window is open in 2021.
- For further assistance with these processes, call the QPP Help Desk at 1-866-288-8292.
If your hardship application is denied, you may re-apply or plan to report MIPS 2020. Our experts are available to assist you with developing a MIPS reporting plan.