The Centers for Medicare & Medicaid Services (CMS) is now accepting applications for the MIPS Extreme and Uncontrollable Circumstances Exception (EUC) and MIPS Promoting Interoperability Performance Category Hardship Exception for the 2022 performance year. Applications can be submitted until 8:00 PM EST on December 31, 2022.

MIPS Extreme and Uncontrollable Circumstance Exception application

Merit-based Incentive Payment System (MIPS)-eligible clinicians, groups, and virtual groups may apply to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances. Extreme and uncontrollable circumstances are defined as rare events entirely outside of your control and the control of the facility in which you practice. These circumstances must:

• Cause you to be unable to collect information necessary to submit for a MIPS performance category
• Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for 3 months), and/or
• Impact your normal process, affecting your performance on cost measures and other administrative claims measures

Applicants, including Alternative Payment Model (APM) entities, can request reweighting of performance categories for the 2022 performance year due to the COVID-19 public health emergency.

For APM entities

APM entities participating in MIPS can also submit a MIPS Extreme and Uncontrollable Circumstances Exception application. However, the following differences exist for APM entities compared to the MIPS EUC policy for individual, groups, and virtual groups:

• APM entities are required to request reweighting for all performance categories
• Additionally, at least 75% of an APM entity’s MIPS-eligible clinicians must qualify for reweighting in the Promoting Interoperability performance category
• Data submission for an APM entity will not override performance category reweighting

Learn more in the 2022 MIPS Extreme and Uncontrollable Circumstances Application Guide.

MIPS Promoting Interoperability Performance Category Hardship Exception Applications

MIPS-eligible clinicians, groups, and virtual groups may apply to reweight the Promoting Interoperability performance category to 0% if they:

• Have decertified EHR technology
• Have insufficient Internet connectivity
• Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues; or
• Lack control over the availability of certified EHR technology (CEHRT); simply lacking the required CEHRT doesn’t qualify you for reweighting

Those who qualify for automatic reweighting of the Promoting Interoperability performance category based on clinician type or special status do not need to submit this application. Small practices qualify for automatic reweighting beginning with the 2022 performance year. Refer to page 16 of the 2022 MIPS Promoting Interoperability User Guide for a complete list of clinician types and special statuses that qualify for automatic reweighting in the 2022 performance year.

Learn more in the 2022 Promoting Interoperability Hardship Application Guide.

How do I apply?

A HCQIS Authorization Roles and Profile (HARP) account is needed to complete and submit an exception application. Sign in to the Quality Payment Program (QPP) website, select “Exceptions Applications” on the left-hand navigation, select “Add New Exception,” and select “Extreme and Uncontrollable Circumstances Exception” or “Promoting Interoperability Hardship Exception.”

How do I know if I’m approved?

Applicants will be notified by email if the request was approved or denied. Application status is also available by signing into the QPP website and navigating to Exceptions. If approved, this information will also be added to your eligibility profile in the QPP Participation Status Tool on a rolling basis. If the application is approved at the end of the performance year, it may not appear in the QPP Participation Status Tool until the submission window is open in 2023.

To learn more, visit the Quality Payment Program website. Contact QPP at 1.866.288.8292 or by email at QPP@cms.hhs.gov.

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