The Centers for Medicare and Medicaid Services (CMS) recently announced that they have identified certain counties in Kentucky as qualifying for a 2022 MIPS extreme and uncontrollable circumstances (EUC) hardship.

This announcement comes in recognition of the severe storms, flooding, landslides, and
mudslides that began in July. The counties reflected in the Kentucky map from the FEMA Kentucky Disaster Declaration below have been included in CMS' list of the counties qualifying for a 2022 MIPS automatic EUC:

• Breathitt County
• Clay County
• Floyd County
• Knott County
• Leslie County
• Letcher County
• Magoffin County
• Martin County
• Owsley County
• Perry County
• Pike County 
• Whitley County

Important Notes for Those in the Identified Counties

• 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 newsletter 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!