For the 2020 performance year, MIPS eligible clinicians, groups, and virtual groups can submit an application to the Centers for Medicare and Medicaid Services (CMS) asking the agency to re-weight one or more performance categories to 0% due to the COVID-19 public health emergency. This means if you have concerns about the impact of the COVID-19 public health emergency on your performance data – including cost measures – you can submit an application to CMS and cite COVID-19 as the reason for your application.
CMS has recently announced that it will be extending the deadline for COVID-19-related 2020 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances Exception applications to February 1, 2021.
If you have concerns about the effect the COVID-19 public health emergency will have on your performance data for the 2020 performance period, including cost measures, submit an application now and make sure you cite COVID-19 as the reason for your application. The deadline to submit a MIPS Promoting Interoperability Performance Category Hardship Exception application or an Extreme and Uncontrollable Circumstances application not related to COVID-19 remained December 31, 2020. If you are already exempt from reporting Promoting Interoperability data, you don’t need to apply.
Once you have an approved application, you can still receive scores for the Quality, Improvement Activities and Promoting Interoperability performance categories if you submit data. If the Cost performance category is included in your approved application, you will not be scored on cost measures even if other data are submitted. It is important to note that you cannot submit an application to override data for program year 2020 that has already been submitted and any data submitted either before or after an application has been approved will be scored.
APM Entities may also submit an application to reweight MIPS performance categories as a result of the COVID-19 public health emergency. Data submitted for an APM won’t override performance category reweighting from an approved application.
How Do I Apply?
You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application either for yourself or another MIPS eligible clinician, group, virtual group or APM Entity. Then you can sign in to qpp.cms.gov, select “Exceptions Applications” on the left-hand navigation, select “Add New Exception,” and select “Extreme and Uncontrollable Circumstances Exception” or “Promoting Interoperability Hardship Exception.”
How do I Know if I’m Approved?
If you submit an application for an exception, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but may not appear in the tool until the submission window is open in 2021.