Automatic 2021 MIPS exemptions granted by CMS

November 24, 2021

Earlier this month, CMS announced individual clinicians required to report Merit-based Incentive Payment System data in the 2021 performance year will be granted an automatic exemption due to the ongoing COVID-19 Public Health Emergency (PHE).

This is the second year in a row participants have been offered an automatic opt-out due to the PHE. The large number of opt-outs continues to drive down potential bonus payments, which are pulled from poor performers due to the program’s requirement to remain budget neutral.

The automatic Extreme and Uncontrollable Circumstances (EUC) policy only applies to MIPS-eligible clinicians who are eligible to participate in MIPS as individuals. The automatic EUC policy doesn’t apply to groups, virtual groups, or Alternative Payment Model (APM) Entities.

Below are CMS’s instructions for determining whether or not the automatic EUC applies to you or your group. If you’re unsure whether you’ll be granted the automatic opt-out, you may also manually apply for the EUC and state COVID-19 as your reason for doing so. Those granted an EUC will receive no payment adjustment in the corresponding 2023 payment year.

Individuals

You don’t need to take any action to have the automatic EUC policy applied to you. You’ll be automatically identified and will have all 4 MIPS performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless you 1) submit data in 2 or more performance categories, or 2) have a higher final score from group or APM Entity participation. 

Small practices reporting Medicare Part B claims measures

Under current policies, we automatically calculate a quality score from Medicare Part B claims measures at the individual and group level.

  • Clinicians in small practices that report Medicare Part B claims measures who are only eligible to participate in MIPS as part of a group aren’t covered by the automatic EUC policy and will receive the group’s final score. (To identify these clinicians, sign in to qpp.cms.gov, navigate to the “Eligibility & Reporting” page and click “View Clinician Eligibility”. Clinicians who are only eligible to participate as part of a group will have a green check mark next to “Group”; there won’t be a green check mark next to “Individual”.)
  • Some small practices may not be aware of the implications of their PY 2021 claims reporting due to some of the policies we introduced at the onset of the COVID-19 PHE.
  • As a result, these small practices may wish to request performance category reweighting on behalf of the group through the PY2021 EUC Exception Application, citing COVID-19 as the triggering event.
  • PY2021 EUC Exception Applications can be submitted by signing in to qpp.cms.gov and clicking Exception Applications on the left-hand navigation.

Groups

The automatic EUC policy doesn’t apply to groups. You don’t need to take any further action if you’re not able to submit data for the 2021 performance year. Group participation is optional (specific guidance for small practices noted above), and your individually eligible MIPS eligible clinicians qualify for the automatic EUC policy if you don’t report at the group-level on their behalf. (If you submit data at the group level on behalf of your MIPS eligible clinicians, the group will receive a MIPS final score based on the data submitted.)

Your MIPS eligible clinicians will have all 4 performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless 1) they submit data in 2 or more performance categories, or 2) they have a higher final score from group or APM Entity participation.

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