2018 MIPS Disaster Relief Hardship Exemptions for Hurricanes and Wildfires posted by CMS

Date: December 11, 2018

CMS announced last week that those providers and practices who are affected by Hurricanes Florence and Michael, or the Wildfires in California, will automatically receive a 2018 MIPS exemption.  The address that is associated in the PECOS system will be how CMS identifies you.

CMS posted its 2018 “Extreme and Uncontrollable Circumstances” policy on its webpage here.  It states:

  • “In the CY 2019 [MPFS] Final Rule, we finalized that this automatic policy will extend to future years of MIPS, beginning with the 2018 MIPS performance period so we can continue to reduce burden for MIPS eligible clinicians facing extreme and uncontrollable circumstances affecting entire regions or areas.
  • “The automatic extreme and uncontrollable circumstances policy applies to MIPS eligible clinicians who are located in a … designated region that has been affected by an extreme and uncontrollable event (such as FEMA-designated major disaster) during the 2018 MIPS performance period … we’ve tried to lessen your burden by not requiring you to submit an application to reweight the performance categories under MIPS.
  • The automatic exemption does not apply to practices that are part of an Alternative Payment Model (APM). Few eyecare providers are currently in APMs, CMS notes in the policy that those in an APM can still apply for an exemption in the Promoting Interoperability (PI) area.

They also stated that if you are not in an APM (most all providers) and accept the automatic exemption, all 4 of the categories in MIPS will be scored at 0% – and that MIPS-eligible providers will automatically be given a 2018 MIPS composite score which results in a neutral payment adjustment in 2020.

Providers can elect to “opt-in” to MIPS and their score will be counted if they submit in two or more categories.  Scores are also counted if you are “…  part of a group or virtual group that submits data …”.

The list of counties affected is shown on the Federal Emergency Management (FEMA) webpage for each of these disasters.  You can link to those FEMA pages below:

  • Hurricane Florence – for NC, link here. For SC, link here.
  • Hurricane Michael – for FL, link here. For GA, link here.
  • California Wildfires – link here to the main FEMA disaster page.

Our thoughts and prayers go out to all affected.

We are happy to assist providers and groups in any way with other topics including QPP attestations, proper code selection, chart reviews, payer actions, and can also provide training on these or other subjects.  Please contact us via one of the below links or on our “App”, Corcoran 24/7, which can be accessed via one of the links below.

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