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

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

The application is open now and can be completed by visiting the application website and clicking on "Apply" under "Extreme and Uncontrollable Circumstances Exception Application Window is Now Open" and choosing the "Extreme and Uncontrollable Circumstances Exception Application."

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.

References:

• CMS Announces MIPS 2020 Performance Year Flexibilities
• APMA Comments to CMS in Response to and in Support of Changes to the 2019 MIPS Performance Year Reporting Requirements (PDF)
• CMS Announces Relief for Clinicians, Providers, Hospitals and Facilities Participating in Quality Reporting Programs in Response to COVID-19
• MLN Connects Newsletter: COVID-19 Quality Reporting Programs Guidance Memo (PDF)
• CMS Fact Sheet: Quality Payment Program – COVID-19 Response (PDF)