In response to the Change Healthcare cyberattack in late February, CMS extended the 2023 MIPS data submission deadline and is now reopening the 2023 MIPS Extreme and Uncontrollable Circumstances (EUC) Exception Application. The deadline for both the EUC application and 2023 data submission is now April 15, 2024, at 8 p.m. ET.
IMPORTANT: Because CMS is reopening the 2023 MIPS EUC Exception Application window in response to the Change Healthcare cyberattack, CMS will only approve applications citing this cyberattack as the basis for requesting reweighting under the MIPS EUC Exception. Any applications submitted for reasons outside of the Change Healthcare cyberattack will be denied. Additionally, any data submitted to CMS will override your application for those performance categories.
Who can submit a 2023 MIPS EUC Exception Application?
Individual MIPS eligible clinicians, groups, virtual groups, and Alternative Payment Model (APM) Entities participating in MIPS (including Shared Savings Program Accountable Care Organizations) who anticipate being unable to submit data for the 2023 performance year, or complete their data submission, before the extended deadline because of the Change Healthcare cyberattack can submit a 2023 MIPS EUC Exception Application. They can apply to request reweighting for any or all MIPS performance categories.
For example:
- You’re a solo practitioner or small practice that does your own billing and submits your own MIPS data, but you’ve had to focus your administrative resources on the numerous workarounds required to get your current claims submitted.
- You’ve hired a third-party intermediary to support your data submission, but they’re engaged in the critical work of redirecting claims and remittance through other clearinghouses so that their clients can stay financially solvent.
What If we’ve already submitted some data?
CMS will NOT reweight any performance category for which they’ve received data.
However, if three of the performance categories are reweighted to 0% and only one performance category can be scored (e.g., because the MIPS eligible clinician submitted data for that category), then the MIPS eligible clinician will earn a final score equal to the performance threshold and the MIPS eligible clinician will receive a neutral payment adjustment.
For example:
- A MIPS eligible clinician in a small practice reported Medicare Part B claims quality measures during the performance period, resulting in a quality score. Because CMS received data, they won’t reweight the quality performance category.
- If the other three performance categories were approved for reweighting to 0% (and no data was submitted for the improvement activities or Promoting Interoperability categories), the quality performance category would be weighted at 100% of the final score, resulting in a final score of 75 points (the performance threshold). This will result in a neutral payment adjustment.
How do I apply?
- Sign in to the QPP website.
- Select ‘Exceptions Applications’ on the left-hand navigation.
- Select ‘Add New Exception’.
- Select ‘Extreme and Uncontrollable Circumstances Exception’.
- Complete the application.
- You MUST select “Ransom/Malware” as the Event Type and include “Change Healthcare cyberattack” in the Event Description.
- Reminder: Any applications submitted for reasons outside of the Change Healthcare cyberattack will be denied.
Applications are reviewed and processed on a rolling basis.
- Don’t wait for the April 15 deadline if the Change Healthcare cyberattack is currently preventing you from submitting data, or if you anticipate that it might.
For More Information on the MIPS EUC Exception Application:
- Review the 2023 MIPS Extreme and Uncontrollable Circumstances Exception Application Guide (PDF, 1MB).
For more timely information related to the Change Healthcare cyberattack, please refer to today’s “Need to Know” section of College Insider. The Advocacy Council will continue to monitor this critical issue and provide you with the information you need.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
