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CMS Announces New 2020 MIPS Hardship

CMS Hardship 2020 MIPS

On February 25, 2021, the Centers for Medicare and Medicaid Services (CMS) announced that they are making the following important changes to the 2020 MIPS extreme and uncontrollable circumstances (EUC) hardships:

  • Extending the deadline for MIPS COVID-19 EUC applications to March 31, 2021.
  • Applying the MIPS automatic EUC policy to all individual MIPS eligible clinicians
    • For more details on what this means, read the “Important Notes” section of this blog.

This announcement comes in the midst of and in recognition of the continuing COVID-19 public health emergency.

Important Notes

  • The Automatic EUC applies only to individual MIPS eligible clinicians. It does not apply to groups, virtual groups, or APMs.
    • Non-Claims-based reporters: Group reporting is optional. If you have not and do not report any 2020 MIPS data at the group level, your clinicians will only be evaluated at the individual level (and have the automatic EUC applied).
    • Claims-based Quality reporters: CMS automatically calculates both your individual and group Quality scores. Any clinician in your group who is only MIPS eligible at the group level (and not the individual level) will only have a group score for 2020 MIPS. Thus, it is especially important to make sure that you have either applied for and received a 2020 EUC for all MIPS performance categories or they will receive a payment penalty next year.
    • All individual MIPS eligible clinicians who receive an automatic EUC exception will have Cost reweighted, regardless of whether they choose to report other performance categories.

  • Do not submit data in the categories for which you received a hardship exception or CMS will score those categories.
    • If you get a hardship for all categories:
      • If you submit data on 2+ MIPS categories, CMS will score you on the reported categories and assign you a 2020 MIPS final score and 2022 payment adjustment
      • If you submit data on 1 or fewer MIPS categories (such as claims-based Quality reporters), CMS will assign you a 2020 MIPS score equal to the threshold to avoid a penalty.

Next Steps

  • Share this information with your practice colleagues.
  • Contact your MarsdenAdvisors Client Success Manager if you plan on using the automatic EUC or applying for an EUC.


If you have any questions on this, let us know! 

Jessica Peterson

Written by Jessica Peterson

Jessica Peterson, MD, MPH is the Senior Vice President of Health Policy at the consulting firm MarsdenAdvisors.

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