This week, the Centers for Medicare and Medicaid Services (CMS) announced that they are applying the MIPS automatic extreme and uncontrollable circumstances hardship (EUC) policy to all individual MIPS eligible clinicians.

This is not as straightforward as it sounds though, particularly for any groups that submit quality data codes (also known as PQRS codes) on their claims. 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 reported and do not report any 2021 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 2021 MIPS. Thus, it is especially important to make sure that you have either applied for and received a 2021 EUC for all MIPS performance categories at the group level or they will receive a payment penalty in 2023.

• 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 submit data on 2+ MIPS categories, CMS will score you on the reported categories and assign you a 2021 MIPS final score and 2023 payment adjustment
  • If you submit data on 1 or fewer MIPS categories (such as claims-based Quality reporters), CMS will assign you a 2021 MIPS score equal to the threshold to avoid a penalty.
• If you get a hardship for all categories, CMS will assign you a 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.
• If you’re not a MarsdenAdvisors client and you want hands-on, personalized assistance, contact us and we will have your back.

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