CMS Provides Additional Guidance for 2019 MIPS Reporting

The Centers for Medicare and Medicaid Services has reopened the Extreme and Uncontrollable Circumstances exception application for 2019 reporting for the COVID-19 public health emergency. Along with the reopening of this application, CMS has provided additional guidance to practices that may wish to claim the exception. 


Individual Clinicians

Individual clinicians who started but are unable to complete their data submission must fill out the application (available here). Individual clinicians who have not submitted any 2019 MIPS data by April 30,2020 will qualify for the extreme and uncontrollable circumstances policy automatically and receive a neutral payment adjustment. Individual clinicians who have not submitted any data are not required to complete the application for the exception to be applied.


MIPS Eligible Groups

Groups that have started, but are unable to complete their data submission must complete the application in order to have their missing data categories reweighted to zero (0). MIPS eligible groups are not eligible for the automatic neutral payment adjustment. Instead, eligible clinicians in a MIPS eligible group that have not submitted any data for 2019 will be scored as individual clinicians with a neutral payment adjustment applied to the clinician.

The Extreme and Uncontrollable Circumstances Exception Application is available April 3, 2020 - April 30, 2020 at 8:00 pm ET on the QPP website. When completing the application, make sure that you:

  • Select 1/1/2020 and 4/30/2020 as your start and end dates;
  • Indicate that you are unable to complete your 2019 performance year data submission due to the COVID-19 pandemic; and
  • Select all 4 MIPS performance categories for re-weighting

If your application is approved, all 4 performance categories will be re-weighted and you will receive a neutral payment adjustment for the 2021 payment year.