COVID-19: MIPS Performance Years 2019 to 2021 | Practicing DPMs | APMA
COVID-19: MIPS Performance Years 2019 to 2021

May 21, 2021 Update: The COVID-19 2021 MIPS PY hardship exception is now available, along with the general Extreme and Uncontrollable Circumstances application. Applications for any EUC must be submitted no later than December 31, 2021.

April 1, 2021 Update: The COVID-19 2020 MIPS PY hardship exception application is now closed. CMS has announced a similar exception application for the 2021 MIPS PY, but has not yet provided details. 

February 25, 2021 Update: The COVID-19 2020 MIPS PY hardship exception has been re-opened. See the MIPS 2020 Performance Year section below for details.

MIPS 2021 Performance Year and Reporting - COVID-19 Extreme & Uncontrollable Circumstances (EUC) Exception - Submit by December 31, 2021

CMS has indicated in its final rule for the CY2021 MPFS that this exception will be available to reweight one to all of the performance categories to zero, for a neutral payment adjustment to the 2023 payment year. Applications for this EUC will need to include a brief description of the data collection challenges you faced and how your 2021 performance will be impacted (although there is still no formal documentation requirement).

How to Apply for a 2021 MIPS PY COVID-19 EUC

Follow APMA's step-by-step instructions when applying for a 2021 MIPS PY COVID-19 EUC. Clinicians will need an HCQIS Access Roles and Profile (HARP) account to submit an EUC application. Once you sign in to QPP with your HARP credentials, click “Exceptions Application” on the left-hand navigation and then select “Extreme and Uncontrollable Circumstances.” Learn how to obtain a HARP account in the QPP Access User Guide under the “Register for a HARP Account document” section. All EUC applications—including the COVID-19 EUC application—must be submitted no later than 8 p.m. EST on December 31, 2021.

MIPS 2020 Performance Year and Reporting - COVID-19 Extreme & Uncontrollable Circumstances Exception Application - Now Closed

On June 24, CMS announced that any clinician "significantly impacted" by the COVID-19 public health emergency may submit an Extreme & Uncontrollable Circumstances (EUC) Application to reweight any or all MIPS performance categories for the 2020 PY if they choose. This decision was a welcome announcement after APMA had requested 2020 MIPS flexibilities in communications with CMS.

CMS reopened this application on February 25, 2021, and closed it on March 31, 2021. How it applied and whether or not your practice was eligible for the automatic exception or eligible but required to apply for the exception depended on the size of your practice and how many performance categories you had already submitted data for.

For more information about this re-opening and extension of this EUC exception related to COVID-19 for the 2020 Performance year, visit

MIPS White Glove - COVID-19 Relief Webinar and Resources

Need help? Follow APMA's step-by-step instructions, and watch this instructional video:

2019 MIPS Performance Year and Reporting

CMS announced on March 22, 2020, that there will be no penalty in 2021 for MIPS-eligible clinicians, reporting as individuals, who do not submit MIPS data for the 2019 performance year. Such clinicians will be automatically exempted under the extreme and uncontrollable circumstances policy exception. This automatic exception for individual clinicians also extends to clinicians who may have already reported data for only one MIPS performance category. The MIPS participation lookup tool has been updated to reflect this change. Providers can check their status here.

For MIPS eligible clinicians who:

  • have already reported at least two performance categories as an individual;
  • are/were planning to submit any amount of data as a group; and
  • other clinicians who do not qualify for the automatic extreme and uncontrollable circumstances policy,

CMS has re-opened the 2019 extreme and uncontrollable circumstances application. These clinicians must proactively submit their application and request that all four performance categories be re-weighted to zero percent. This application must be submitted by April 30, 2020.

The application is available to:

  • clinicians reporting as individuals who started by submitting data for more than one category, but are unable to complete, their data submission;
  • small practices that were automatically scored as a group on Medicare Part B claims quality measures;
  • groups that started, but are unable to complete, their data submission; and
  • virtual groups that are unable to start or complete their data submission.

Clinicians can submit the application here. When completing the application, please make sure that you:

  • select individual, group, or virtual group as appropriate to your level of participation;
  • select 1/1/2020 and 4/30/2020 as your start and end dates;
  • indicate that you are unable to complete data submission due to the COVID-19 pandemic; and
  • select all four performance categories for reweighting.

An extreme and uncontrollable circumstance application submitted between April 3–April 30, 2020, citing COVID-19, and approved by CMS, will override any previous data submission.


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