American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

How to Apply for a MIPS Exception in 2021

2021 Extreme and Uncontrollable Circumstances Exception Application

For 2021, the Extreme and Uncontrollable Circumstances Reweighting Application allows individual clinicians, group practices, and APM Entities to request reweighting for any or all MIPS performance categories should they encounter an extreme or uncontrollable circumstance that disrupts their ability to participate in MIPS.

Examples of an extreme and uncontrollable circumstance for 2021 include:

  • A natural disaster, such as a hurricane, tornado, etc.
  • A public health emergency (PHE), such as the COVID-19 pandemic.

Clinicians will have until at least the end of 2021 to submit an Extreme and Uncontrollable Circumstances Reweighting application for the 2021 performance year. CMS will post additional details about this process throughout the year on the QPP website.

2021 Automatic Extreme and Uncontrollable Circumstances Policy

Note that individuals, groups and virtual groups cannot submit an application to override PY2021 data that has already been submitted. Any data submitted as an individual, group or virtual group before or after an application has been approved will be scored.

There are also instances where CMS applies the extreme and uncontrollable circumstances policy automatically to certain clinicians. Individual clinicians located in a CMS-designated region that has been affected by an extreme and uncontrollable circumstance are not required to submit an application to have their performance categories reweighted. These clinicians will automatically receive a score equal to the performance threshold, which will result in a neutral payment adjustment (neither a positive nor a negative adjustment) unless:

  • The clinician submits data for two or more MIPS performance categories as an individual, which voids the zero percent performance category weight on a category-by-category basis.
  • The clinician is part of a group that submits data on behalf of its clinicians; or
  • The clinician is part of a virtual group.

This automatic exception only applies to individual clinicians and does not apply to groups or virtual groups.

CMS will communicate information about events that trigger the automatic extreme and uncontrollable circumstances policy through its QPP listserv and fact sheets. Clinicians may also find information about designated disaster areas on the FEMA designated disaster areas page. As of late January 2021, CMS has not identified the COVID-19 pandemic as a triggering event for the automatic extreme and uncontrollable circumstances policy for the 2021 performance period.

MIPS Promoting Interoperability Performance Category Hardship Exception

To participate in the Promoting Interoperability performance category, clinicians must use certified electronic health record technology (CEHRT). Under MIPS, clinicians and groups may qualify for re-weighting of the PI performance category to 0% if they submit an application and meet the criteria below:

  • You are a small practice
  • You have a decertified EHR technology
  • You have insufficient internet connectivity
  • You face extreme and uncontrollable circumstance such as disaster, practice closure, severe financial distress or vendor issues
  • You lack control over the availability of CEHRT

How to Apply for Hardship Exceptions

  • First, you will need a HCQIS Access Roles and Profile (HARP) account to submit a hardship exception application.
  • Once you sign into the QPP website with your HARP credentials, select 'Exceptions Application' on the left-hand navigation and then select either 'Promoting Interoperability Hardship' or 'Extreme and Uncontrollable Circumstances.'

How to Know If Your Application Was Approved

You will be notified if your application is approved or denied via email. Your application status will also be added to your account on the QPP website and on the Participation Status Look Up tool. If your application is approved, you do not have to report data for your selected performance categories and the categories will be reweighted.

Please note: If you qualify for automatic reweighting or have an approved exception application, should you submit data for two or more performance categories (or the PI category if you qualify for the PI Hardship Exception) the categories for which you submitted data will be scored and override the Exception reweighting.

Additional information about the 2021 Promoting Interoperability Hardship Exception will be posted on the QPP website throughout the year.