Clinicians not automatically included in MIPS exception must apply by year's end

Applications for “extreme and uncontrollable circumstances” exceptions for the 2021 Merit-based Incentive Payment System (MIPS) performance year are due Dec. 31. The Centers for Medicare & Medicaid Services (CMS) announced in November that it will automatically apply the exceptions for many clinicians, but there are still some eligible clinicians who need to apply.

In general, clinicians who are eligible to participate in MIPS as an individual (i.e., exceed the low-volume threshold, are not in their first year of Medicare participation, and are a qualifying participant in an advanced alternative payment model) do not need to apply. CMS will automatically reweight all four performance categories to 0% and they will receive a neutral payment adjustment in 2023 unless they submit data in two or more performance categories or have a higher final score from group or APM participation.

Clinicians in small practices that report via Medicare Part B claims and are only eligible to participate in MIPS as a group will need to apply to have their performance categories reweighted. Clinicians can review their eligibility by logging into the Quality Payment Program website. Once logged in, navigate to the “Eligibility & Reporting” page and click “View Clinician Eligibility.” Those who are only eligible to participate as a group will see a green checkmark next to “Group” and will not have a green checkmark next to “Individual.”

Eligible clinicians in virtual groups will also need to apply for reweighting. If they submit no data, the clinicians will likely receive the maximum negative payment adjustment of -9% in 2023.

Clinicians who submit an extreme and uncontrollable circumstances application should cite COVID-19 as the triggering event.

Additional information is available in the Quality Payment Program – COVID-19 Response, 2021 MIPS Automatic Extreme and Uncontrollable Circumstances Policy, and 2021 MIPS Extreme and Uncontrollable Circumstances Exception Application Guide. You can contact the Quality Payment Program by phone at 866-288-8292, Monday through Friday, 8 a.m. to 8 p.m. ET, or by email.

— Erin Solis, manager of practice and payment, American Academy of Family Physicians

Posted on Dec. 22, 2021, by Erin Solis