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Extreme and Uncontrollable Circumstances Hardship Exemption Available for MIPS-Eligible Clinicians Affected by California Wildfires and Hurricanes Florence and Michael

For clinicians who experienced an extreme and uncontrollable circumstances, such as Hurricane Florence, Hurricane Michael, or the California wildfires, and had difficulties collecting and submitting data for the Merit-Based Incentive Payment System (MIPS) on time during the 2018 MIPS performance period, CMS is creating an automatic MIPS hardship exemption to ensure no penalty for 2020 payment year.

How Does It Work?

CMS will identify MIPS-eligible clinicians who are located in CMS-designated areas that have been affected by an extreme and uncontrollable circumstance based on the address associated with the clinician in the Provider Enrollment, Chain, and Ownership System (PECOS).

For MIPS-eligible clinicians who are subject to the policy, all four performance categories will be weighted at zero percent (0%). They will automatically receive a score equal to the performance threshold, which will result in a neutral payment adjustment (neither a positive or negative adjustment) for the 2020 MIPS payment year unless: 

  • The clinician submits data for two or more MIPS performance categories (Quality, Improvement Activities, and/or Promoting Interoperability) as an individual; or
  • The clinician is part of a group or virtual group that submits data on behalf of its clinicians.

Clinicians do not need to submit a separate application for this hardship; CMS will apply it automatically.

Please note that MIPS-eligible clinicians in MIPS APMs are not covered by the automatic extreme and uncontrollable circumstances policy. However, a MIPS-eligible clinician in a MIPS APM and identified as affected by an extreme and uncontrollable circumstance may apply for an exception in the Promoting Interoperability performance category.

More information can be found in the MIPS Automatic Extreme and Uncontrollable Circumstances Policy fact sheet.

For more information, please contact Jillian Winans, regulatory affairs specialist, at jwinans@ascrs.org or 703-591-2220.