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CMS Automatic Extreme & Uncontrollable Circumstances Exception for 2020 MIPS

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. 

CMS has also reopened the application for the 2020 MIPS Extreme and Uncontrollable Circumstances Exception for COVID-19. The new deadline is March 31, 2021 8:00 PM ET.

What does this mean if I have already submitted data?

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

  • Individual MIPS eligible clinicians who HAVE NOT submitted any data, 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.
  • Individual MIPS eligible clinicians who have submitted data for 1 performance category, you don’t have to take any action and you will be eligible for the automatic EUC exception.
  • Individual MIPS eligible clinicians who have submitted data for 2 or more performance categories, you WILL receive a MIPS final score and MIPS payment adjustment for the 2022 MIPS payment year based on the data you’ve submitted. You can’t submit an application to override previously submitted data.

Reminder: The 2020 MIPS performance year data submission deadline is also March 31, 2021. For more information please visit the QPP website.

Questions? Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, consider calling during non-peak hours—before 10 AM and after 2 PM ET.