CMS re-opens MIPS Hardship Exception for Groups, Virtual Groups, and APM entities

Date: March 24, 2022

The Centers for Medicare & Medicaid Services (CMS) announced March 3 that they re-opened the 2021 Extreme and Uncontrollable Circumstances (EUC) application for those submitting as groups, virtual groups, or APMs.  You may recall that all individual providers eligible for MIPS 2021 already have been granted a hardship exception “in their pocket” such that they get no penalty in 2023 but could still submit for 2021 (most likely because they can earn a bonus).  We wrote about that in a prior WebNews in November, 2021, which you can link to here.

In the update to the policy on the QPP webpage announcing this re-opening, CMS noted the following:

We’ve applied the MIPS automatic extreme and uncontrollable circumstances policy to all individual MIPS eligible clinicians for performance year 2021. We’ve also reopened the 2021 MIPS EUC application to allow groups, virtual groups and APM Entities to submit an application requesting MIPS performance category reweighting due to the ongoing COVID-19 public health emergency. (Because of the automatic EUC policy, individual clinicians don’t need to submit an application.)

This re-opening for groups, virtual groups, or APMs is only available until Thursday March 31, 2022 at 8 PM Eastern time.  You do the application by signing into your QPP account at this link:  https://qpp.cms.gov/login.  For those of you who have never logged into to QPP, the same link allows you to register.

As noted before in our prior WebNews, the downside to taking this hardship exception is that, because of budget neutrality provisions built into QPP and the Merit-Based Incentive Payment System (MIPS), there will be far fewer penalties in 2021 – and as a result, significantly fewer bonuses for the payment year 2023 for those who do actually make a high enough score.

We are available and happy to assist you with issues related to eye care coding and reimbursement.  We are available to present our webinars related to the significant changes for 2022 QPP/MIPS and the 2021 Evaluation and Management eye exam coding.  This new full program includes a large, completely revised text and new Office Visit Guide pocket guides, so contact us if you are interested.  Stay safe.  

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