On September 27, 2021, the Centers for Medicare and Medicaid Services (CMS) announced that they are reopening the applications for 2020 MIPS extreme and uncontrollable circumstances (EUC) hardships due to COVID-19. 

• The deadline to submit a new 2020 MIPS COVID-19 EUC application is Nov. 29, 2021 at 8pm ET.
• Applications must be submitted through the targeted review process.
  • For more details on what this means, read the “How to Apply” section of this blog.

Due to the continued impact of the COVID-19 pandemic, CMS realized that many were unable to complete the EUC application for performance year 2020 by the previous March 31, 2021 deadline.

Important Notes

• The deadline to submit 2020 MIPS COVID-19 EUC applications is Nov. 29, 2021 at 8 pm ET.
• Applications must be submitted through the targeted review form (see "How to Apply" below).
• This application does not apply to:
  • Individual MIPS-eligible clinicians as they already received an automatic EUC at the individual level for 2020 MIPS.
  • Any performance category for which the applicant submitted data.
    • CMS "won't reweight any performance category for which an individual, group or virtual group submitted data."
• This does apply to individual clinicians who are only eligible at the group level.
  • Clinicians who are not individually MIPS eligible whose group reported claims and nothing else should apply for this hardship as they were not eligible for the automatic 2020 MIPS EUC hardship and would, otherwise, receive a 2022 penalty.
• If you are granted a hardship:
  • If you have 1 or 0 MIPS categories remaining after the hardship is applied, CMS will assign you a 2020 MIPS score equal to the threshold to avoid a penalty. You will not receive any 2022 MIPS payment adjustments.
  • Retain documentation of the hardship for at least six years in case of an audit.

How to Apply

If you are a MarsdenAdvisors client, contact your Client Success Manager to complete this process for you.

If you are not a MarsdenAdvisors client, apply using the following steps:

1. Sign in to your HARP account.
2. Select "Targeted Review" on the left-hand navigation.
3. Select the application level -- individual, group, virtual group, or APM Entity level.
4. Select the performance category or categories for your reweighting application.
5. Under "Issue Selection", select "Extreme and uncontrollable circumstances".
6. Enter your zip code and provide dates of the circumstance.
7. Provide details of your EUC request. You will need to specify that you're submitting an EUC request due to COVID-19. CMS also encourages applicants to restate the performance categories for which you are applying for reweighting in this section.
8. Scroll to the bottom of the page and click "Submit for Review".
9. After you submit your application, you will receive a message and an email stating that your application has been successfully submitted and is pending review.
10. Once your application has been reviewed and a decision has been made, CMS will post the decision to your HARP account. You can also monitor your application status from there.
11. Retain documentation of the hardship for at least six years in case of an audit.

Next Steps

• Share this information with your practice colleagues.
• Contact your MarsdenAdvisors Client Success Manager if you plan on applying for a 2020 EUC. Your Client Success Manager will submit the application and retain the necessary documentation on your behalf.

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