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Florida and Puerto Rico Now Qualify for 2022 MIPS Automatic Hardships


CMS Hardship MIPS 2022

The Centers for Medicare and Medicaid Services (CMS) recently announced that they have identified the State of Florida and the territory of Puerto Rico as qualifying for a 2022 MIPS extreme and uncontrollable circumstances (EUC) hardship.

This announcement comes in recognition of the impact of Tropical Storm Ian, which struck Florida on September 28, 2022 and Hurricane Fiona, which struck Puerto Rico on September 18, 2022. The entirety of both Florida and Puerto Rico are reflected in the maps from the FEMA Florida Disaster Declaration and the FEMA Puerto Rico Disaster Declaration below and have been included in CMS' list of the areas qualifying for a 2022 MIPS automatic EUC:

Screen Shot 2022-10-25 at 3.35.00 PM

Important Notes for Those in the Identified Areas

  • The Automatic EUC applies only to individual MIPS eligible clinicians. It does not apply to groups, virtual groups, or APMs.
    • Group reporting is optional. If you have not reported and do not report any 2022 MIPS data at the group level, your clinicians will only be evaluated at the individual level (and have the automatic EUC applied).
      • You can still report on the individual level, if you would like.
    • 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 2022 MIPS final score and 2024 payment adjustment.
    • If you submit data on 1 or fewer MIPS categories, CMS will assign you a 2022 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 colleagues.
  • Subscribe to our blog to get alerts on this and other important issues. You can subscribe using the field in our website footer below. 
  • If you are a MarsdenAdvisors client
    • Contact your Client Success Manager if you have any questions or if you plan on using this automatic hardship. Your Client Success Manager will help you evaluate your eligibility and retain the necessary documentation on your behalf.
  • If you are not a MarsdenAdvisors client
    • Contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.

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

Juliette Walle

Written by Juliette Walle

Juliette Walle is a Health Policy Analyst at the consulting firm MarsdenAdvisors.

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