Are you required to participate in the Merit-based Incentive Payment System (MIPS) in 2021? If so, you can opt out and avoid a potential 9% penalty by completing an Extreme and Uncontrollable Circumstances Exception application due to COVID-19. Applications are now open for the Extreme and Uncontrollable Circumstances Exception. The submission deadline is Dec. 31.
Practices can request to reweight any or all MIPS performance categories under this exception by submitting an application stating their practice has been significantly impacted by the COVID-19 public health emergency:
- Practices that receive a hardship exemption in all four categories will avoid a MIPS penalty.
- However, if a clinician or group submits data in two or more MIPS categories for the 2021 performance period, the data submission will override the exception, and the clinician or group will be scored on the data submitted.
To determine if you are required to participate in MIPS in 2021, check your MIPS participation status. The potential penalty for nonparticipation is 9% – unless you apply and are granted the exception. If you do participate in MIPS but don’t report all required data and/or your MIPS performance is poor, you could get a lesser penalty of up to 9%. Penalties or bonuses from 2021 MIPS performance will impact payment in 2023.
How do you apply for an exception?
To submit an Extreme and Uncontrollable Circumstances Application you must first create a HCQIS Access Roles and Profile (HARP) account. For more information on how to obtain a HARP account, download the QPP Access User Guide and refer to the Register for a HARP Account document.
Once you sign into QPP with your HARP credentials, click Exceptions Application on the left-hand navigation and then select Extreme and Uncontrollable Circumstances.
How do you know if you’re approved?
If you submit an application for an exception, you’ll be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool.
For more information, you can download the 2021 MIPS Promoting Interoperability Hardship Exception Application Guide. If you have questions, please contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov.
If you plan to participate in MIPS this year, we’ll provide guidance on participation next week (5/31) in the Advocacy Insider. The Advocacy Council will continue to monitor this issue and notify you of any changes – we have you covered.