The Centers for Medicare & Medicaid Services (CMS) reopened the Extreme & Uncontrollable Circumstances (EUC) application and indicated they will automatically apply the policy to individuals who do not submit data for 2020 Merit-based Incentive Payment System (MIPS). Here is what the changes mean for your practice based on your current 2020 MIPS reporting status.
Individual Reporting
If you have already submitted MIPS 2020 data in two or more categories to the CMS, you will receive a score and payment adjustment based on that data for payment year 2022 as expected.
If you have already submitted MIPS 2020 data in only one category to the CMS and do NOT submit data in any additional categories, you will receive the EUC automatically. All categories will be reweighted to 0% and you will receive a neutral payment adjustment in 2022.
If you have NOT submitted MIPS 2020 data and do NOT submit any data by the March 31 deadline, you will receive the EUC automatically. All categories will be reweighted to 0% and you will receive a neutral payment adjustment in 2022.
Group Reporting
If you have already submitted MIPS 2020 data in two or more categories to the CMS, you will receive a score and payment adjustment for payment year 2022 as expected.
If you have already submitted MIPS 2020 data in only one category to the CMS and do not submit data in any additional categories, you can submit an EUC application to reweight all four performance categories; if your application is approved, you will receive a neutral payment adjustment for payment year 2022. If you do not submit an EUC application, your group will be scored in all four performance categories unless the group qualifies for reweighting in one or more performance categories.
If you have NOT submitted MIPS 2020 data and all clinicians in your group are MIPS eligible, you do not need to take any further action. Your MIPS-eligible clinicians will qualify for the automatic EUC policy.
If you have NOT submitted MIPS 2020 data, you do not intend to submit MIPS 2020 data and your group has some MIPS-eligible clinicians and some non-eligible clinicians, you should complete the EUC application.
More Information
All individuals and groups may still choose to submit data for MIPS 2020 to receive a score and payment adjustment as usual. The CMS’ decision to reopen the EUC is due to the continuing impact of the COVID-19 pandemic on practices across the country. For more information about this policy, see the 2020 MIPS Extreme & Uncontrollable Circumstances Resources and Quality Payment Program COVID-19 Response from the CMS, or visit the CMS website.
