MIPS Hardship Policy

Medical Billing

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Due to the COVID-19 public health emergency, the Centers for Medicare & Medicaid Services (CMS) will be applying the MIPS extreme and uncontrollable circumstances (EUC) policy automatically for all eligible clinicians for the 2020 performance period. This policy applies to providers that are unable to submit sufficient MIPS data for the 2020 reporting year during the submission period. MIPS eligible individual providers will not be required to submit an application to reweight the MIPS performance categories.

However, the enforcement of the EUC policy does not automatically apply to groups or virtual groups. Groups, virtual groups, and Alternative Payment Model entities wishing to request reweighting of any or all of the MIPS performance categories due to COVID-19 must submit an EUC exception application by the extended deadline of March 31, 2021. Groups that do not apply for EUC will be scored by the existing MIPS scoring policies. The individual clinicians in the group will receive the payment adjustment associated with the group’s final score unless their individual participation score is higher. Virtual groups will be scored according to the existing MIPS scoring policies regardless of data submission and the eligible clinicians in the group will receive the payment adjustment associated with the group’s final score.

The four MIPS performance categories are Quality, Promoting Interoperability, Improvement Activities, and Cost. The MIPS Cost category is calculated automatically based on data from claims and does not require reporting. There are concerns, however, that COVID-19 will have significant effects on the cost measures. For that reason, the cost category will be weighted at zero percent under the automatic EUC policy even if data is submitted for any or all of the other performance categories. If a practice covered under the EUC policy does not submit data for any of the other (3) categories, they will receive a neutral or no payment adjustment for the 2020 MIPS performing year (the 2022 MIPS payment year). If data is submitted for only one of the three categories, that category will be weighed for 100% of the score and the practice will receive a neutral or no payment adjustment under the EUC policy. If data is submitted for two or more of the three performance categories, each category will be weighed according to the table (Appendix A) published by the CMS and a positive, negative, or neutral payment adjustment will be issued for the 2022 MIPS payment year.

If you believe that you qualified for the automatic EUC policy and it does not appear to be reflected in your performance feedback, you can submit a targeted review within 60 days following the release of your 2020 performance feedback. 

Works Cited: Scoring, 42 C.F.R. §414.1380. (2021). 

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