As an additional COVID-19 flexibility, CMS is applying the MIPS automatic extreme and uncontrollable circumstances (EUC) policy to all MIPS eligible clinicians for the 2020 performance period.

Additionally, CMS has reopened the deadline to complete an extreme and uncontrollable circumstances application for PY 2020. The previous deadline was Monday, February 1, 2021. However, the NEW deadline is March 31, 2021 at 8:00 PM ET.

Note that applications received between now and March 31, 2021 won’t override previously submitted data for individuals, groups and virtual groups.

Individual clinicians, groups, and virtual groups that haven’t submitted data.

• Individual MIPS eligible clinicians: You don’t need to take any additional action to qualify for the automatic EUC policy. You will be automatically identified and will receive a neutral payment adjustment for the 2022 MIPS payment year unless 1) you submit data as an individual in 2 or more performance categories, or 2) your practice reports as a group, by submitting data for one or more performance category.
• Groups: You don’t need to take any further action if you’re not able to submit data for the 2020 performance period. Group participation is optional, and your individual MIPS eligible clinicians qualify for the automatic EUC policy. They will have all 4 performance categories reweighted to 0% and receive a neutral payment adjustment for the 2022 MIPS payment year unless 1) they submit data in 2 or more performance categories as individuals, or 2) the practice reports as a group, by submitting data for one or more performance category.
• Virtual Groups: If you’re unable to submit data for the 2020 performance period, you must submit an EUC application for all 4 performance categories by the deadline.

Individual clinicians, groups, and virtual groups that have submitted data.

• Individual MIPS eligible clinicians that have submitted data for a single performance category (such as Medicare Part B Claims measures submitted throughout the 2020 performance period):
  • You don’t need to take any additional action to be eligible for the automatic EUC policy.
  • You’ll be automatically identified and have all 4 performance categories reweighted to 0% and will receive a neutral payment adjustment for the 2022 MIPS payment year unless 1) you submit data for another performance category, or 2) your group submits data for one or more performance category.
• Individual MIPS eligible clinicians that have submitted data as an individual for 2 or 3 performance categories:
  • You’ll receive a MIPS final score and MIPS payment adjustment for the 2022 MIPS payment year based on the data you’ve submitted.
  • You’ll only be scored in the performance categories for which data are submitted.
  • You can’t submit an application to override previously submitted data.

Resources:

• QPP Exception Applications webpage
• 2020 MIPS Extreme and Uncontrollable Circumstances Application Resources
• Quality Payment Program COVID-19 Response fact sheet