The Centers for Medicare and Medicaid Services (CMS) recently announced that COVID-19 will be an acceptable reason for applying for MIPS Extreme and Uncontrollable Circumstances Flexibilities for the 2021 performance period.
This is the third MIPS performance year that eligible providers and groups have been allowed to apply for flexibilities based on COVID-19. In March 2020, CMS automatically applied its extreme and uncontrollable circumstances (EUC) policy to all MIPS eligible clinicians who had not submitted data for the 2019 performance year. CMS also re-opened EUC applications for any eligible groups and providers that had already submitted data.
Then, in early 2021, CMS once again automatically applied its EUC policy to all MIPS eligible clinicians for the 2020 performance year depending on what data, if any, eligible providers and groups had already submitted at the time.
According to CMS, the EUC policy will not be applied automatically for the 2021 performance period, however, since “not all practices have been impacted by COVID-19 to the same extent.” Clinicians, groups, virtual groups, and APM Entities that continue to be impacted by the COVID-19 public health emergency, which was recently extended by Xavier Becerra, Secretary of the Department of Health and Human Services, can submit an application requesting reweighting of performance categories for 2021.
The Extreme and Uncontrollable Circumstances Exception Application deadline for 2021 is December 31, 2021, at 8 p.m. ET. To apply, providers will need a HCQIS Access Roles and Profile (HARP) account. After signing into QPP with HARP credentials, users should click ‘Exceptions Application’ on the left-hand navigation and then 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.
Applicants will be notified by email if their request was approved or denied, and the information also will be available by signing into QPP. Eligible clinicians who are granted an EUC exception do not have to report data for the requested MIPS performance category or categories, and those categories will be reweighted. However, if data is submitted for two or more MIPS performance categories, providers will receive a final score based on their performance in those categories.
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