Appendix I 2022 MIPS Extreme and Uncontrollable Circumstances Excep

 

Contents

How to Use This Guide                                                           3

Extreme and Uncontrollable Circumstances Application Overview           5

Extreme and Uncontrollable Circumstances Application Process:

Frequently Asked Questions                                                 13

Extreme and Uncontrollable Circumstances Application Process:

Application Steps                                                         16

Help, Resources, Glossary, and Version History                                 29

Appendices                                                                 33

 

How to Use This Guide

 

How to Use This Guide

 

Extreme and Uncontrollable Circumstances Application Overview

 

Extreme and Uncontrollable Circumstances Application Overview

Overview

We understand that there may be circumstances out of your control that make it difficult for you to meet program requirements. To reduce this burden, we provide an opportunity for qualifying clinicians, groups, virtual groups and Alternative Payment Model (APM) Entities to apply for performance category reweighting for MIPS.

What	The MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application allows you to request reweighting for one or more performance categories to 0%. See Appendix A1, Appendix A2, and Appendix B for more information on performance category reweighting in traditional MIPS and the APM Performance Pathway (APP).
Who	Individual clinicians, groups, virtual groups, and APM Entities •Third Party Intermediaries can submit an application with permission from the clinician or practice.
Why	You can submit an application to have your MIPS quality, cost, improvement activities, and/or Promoting Interoperability performance categories reweighted to 0% if: •You experience an extreme and uncontrollable circumstance outside of your control, such as a natural disaster, ransomware attack or public health emergency (PHE) (e.g. COVID-19 pandemic), that prevents you from collecting data for an extended period of time, or that could impact your performance on cost measures.     Note: APM Entities are required to request reweighting for all performance categories.
When	Now through January 3, 2023, at 8 p.m. ET.
Where	Sign in to qpp.cms.gov with your HCQIS Access and Roles Profile (HARP) account. You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide (ZIP). Note: APM Entity representatives must have the Security Official role in order to complete the Extreme and Uncontrollable Circumstances exception application on behalf of their entity. Refer to the Connect to an Organization document in the QPP Access User Guide (ZIP) for more information on requesting the Security Official role.
How	1. Register for a HARP account 2. Sign in to qpp.cms.gov  3. Select ‘Exceptions Applications’ on the left-hand navigation 4. Select ‘Add New Exception’ 5. Select ‘Extreme and Uncontrollable Circumstances Exception’ 6. Complete the application for individual, group, virtual group, or APM Entity participation

 

Extreme and Uncontrollable Circumstances Application Overview

EUC applications can be submitted for one or more performance categories.

1. • • •Any performance category that isn’t included in the application is eligible for scoring, even if no data are submitted, unless the clinician or group qualifies for reweighting under another policy. 

Any data you submit, or is submitted on your behalf, will override reweighting for that performance category and the category will be scored.

1. • • •If you later determine that you’re able to collect data for a performance category approved in your application, you can submit that data and it will be scored. 

     • •If the cost performance category is included in the application, cost measures won’t be scored even if data is submitted for other performance categories.  

     • •If you submit Medicare Part B Claims measures during the performance year, this will override quality performance category reweighting. However, if you request and are approved for reweighting in all 4 performance categories and don’t submit data for another performance category, your MIPS final score for the 2022 MIPS performance period would be equal to the performance threshold and you would receive a neutral payment adjustment in 2024. 

You must be scored on at least 2 performance categories to earn a MIPS final score other than the performance threshold.

When fewer than 2 performance categories can be scored (meaning 1 performance category is weighted at 100% of your MIPS final score, and the other performance categories are weighted at 0%), the MIPS final score for the 2022 MIPS performance period would be equal to the performance threshold and you would receive a neutral payment adjustment in 2024.

 

 

Extreme and Uncontrollable Circumstances Application Overview

Intersection Between the Automatic EUC Policy and the Application-Based EUC Policy

If you qualify for reweighting under the automatic EUC policy, then we’ll reweight all 4 performance categories to 0% (rather than just the categories included in your EUC application). We’ll score any performance category for which data is submitted.

Example

Scenario

Outcome

A MIPS eligible clinician who is eligible for the automatic EUC policy has also submitted an EUC exception application. The application was approved for reweighting in the Promoting Interoperability performance category, and the clinician submits data for the quality and improvement activities performance categories.

You will be scored as follows: •The quality and improvement activities performance categories will be scored because you submitted data for those categories  •The cost performance category is reweighted to 0% under the automatic EUC policy.  •The Promoting Interoperability performance category is also reweighted to 0% under the automatic EUC policy.   Note, in this example, the EUC application wasn’t needed to reweight the Promoting Interoperability performance category due to the automatic EUC policy.

 

Extreme and Uncontrollable Circumstances Application Overview

Individual Clinicians, Groups, and Virtual Groups Reporting Via Traditional MIPS

Example

Scenario

Outcome

You’re a MIPS eligible clinician (or group or virtual group) that is planning to report via traditional MIPS. You submit an application to have all 4 performance categories reweighted, but later determine you are able to report the improvement activities and Promoting Interoperability performance categories.

You will receive a MIPS final score based on the data submitted. •The improvement activities performance category will be weighted at 15%.  •The Promoting Interoperability performance category will be weighted at 85%.   •The quality performance category will retain a 0% weight because you didn’t submit quality data.   •The cost performance category will retain a 0% weight because there are no data submission requirements associated with the cost performance category (reweighting can’t be voided).

 

Extreme and Uncontrollable Circumstances Application Overview

Individual Clinicians and Groups Reporting Via APP

Example

Scenario

Outcome

You’re a MIPS eligible clinician (or group) planning to report via the APP. You submit an application to reweight the quality performance category and your application was approved.

You will receive a MIPS final score based on the data submitted. •The improvement activities performance category will be weighted to 25%.   •The Promoting Interoperability performance category will be weighted to 75%.   •The quality performance category will be weighted at 0% provided no data is submitted.   •The cost performance category will retain a 0% weight (because cost isn’t scored under the APP).

 

Extreme and Uncontrollable Circumstances Application Overview

APM Entities

APM Entities

APM Entities in the following models can submit an EUC application on behalf of their MIPS eligible clinicians:

• • •Medicare Shared Saving Program  

  • •Vermont Medicare ACO Model  

  • •Bundled Payments for Care Improvement (BPCI) Advanced Model  

  • •Oncology Care Model (OCM)  

  • •Maryland Total Cost of Care  

  • •Independence at Home Demonstration 

  • •Primary Care First (PCF)  

  • •Value in Opioid Use Disorder Treatment (ViT)  

  • •Direct Contracting (DC)  

  • •Comprehensive Care for Joint Replacement (CJR) Payment 

  • •Kidney Care Choices (KCC) 

 

Extreme and Uncontrollable Circumstances Application Overview

APM Entities (continued)

APM Entity applications must be submitted for all performance categories.

1. • • •You can’t submit an application for an APM Entity to request reweighting in 1 or 2 performance categories. 

     • •This is different from our policy for individual, group, and virtual group applications. 

If your APM Entity’s application is approved, the APM Entity will receive a final score equal to the performance threshold even if data are submitted for the APM Entity.

1. • • •The MIPS eligible clinicians in the APM Entity will receive a neutral MIPS payment adjustment unless they have a higher final score from individual or group participation. 

     • •Data submitted for an APM Entity will not override performance category reweighting from an approved application.  

     • •This is different from our policy for individual, group, and virtual group applications.  

At least 75% of MIPS eligible clinicians in an APM Entity must qualify for reweighting of the Promoting Interoperability performance category.

1. • • •Given that APM Entities are required to request reweighting for all performance categories in their EUC application, at least 75% of the MIPS eligible clinicians in the Entity will need to qualify for reweighting in the Promoting Interoperability performance category. 

     • •They may qualify automatically or by meeting one of the criteria for the MIPS Promoting Interoperability Hardship Exception. 

APM Entity representatives must have a QPP Security Official role to complete the Extreme and Uncontrollable Circumstances exception application on behalf of their entity.

• •Review the Connect to an Organization resource in the QPP Access User Guide (ZIP) for more information on obtaining the Security Official role. 

An approved application won’t affect your model-specific reporting requirements.

1. • • •For example, Shared Savings Program ACOs must report the quality measures identified under the APP to meet their requirements under the Shared Savings Program, unless otherwise excepted under that APM. 

 

Extreme and Uncontrollable Circumstances Application Process: Frequently Asked Questions

 

Extreme and Uncontrollable Circumstances Application Process: Frequently Asked Questions

How Does CMS Assess EUC Application Requests?

 

Extreme and Uncontrollable Circumstances Application Process: Frequently Asked Questions

How Long Does it Take to Process an EUC Exception Application?

• •The length of time it takes to process application requests depends on the volume of requests we receive. We review all application requests in the order that they were received. Once a decision is made regarding your application, you will receive a notice of our decision and the status of your application will be reflected in your QPP Account on qpp.cms.gov. 

Where Can I Look for a Status Update on My EUC Exception Application?

• •You can monitor your application status in your QPP Account on qpp.cms.gov. 

Are We Required to Submit Documentation with Our EUC Exception Application?

• •No, you aren’t required to submit documentation with your application.  

• •However, you should retain documentation of the circumstances supporting your application for your own records in the event that you are selected by CMS for data validation or an audit. See our 2022 MIPS Data Validation Criteria Guide (ZIP) for information on the data validation and audit process.  

How Can I Correct a Mistake Made on Our EUC Exception Application?

• •If you identified an error with your exception application, please contact the Quality Payment Program at 1-866-288-8292, Monday through Friday, 8 a.m.-8 p.m. ET or by e-mail at: [email protected].   

Can Additional Staff Members Access/Receive Notifications About the Status of Our EUC Exception Application?

• •Yes, you can add additional staff or representatives who should receive notifications about the status of the application.  

• •In the Additional Access section of the application, provide the email address(es) of additional staff or representatives who would like to receive email notifications.  

• •Please note that the additional staff or representatives must have a HARP credentials in order to see the application in qpp.cms.gov.  

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 1: Sign in to Your QPP Account

Sign in to your QPP Account at qpp.cms.gov with your HARP credentials.

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 2: Navigate to Your Exception Applications

Once you are signed into your account select:​

1. • •The Exception Application tab in the left-hand navigation menu, then click + Add New QPP Exception​ 

          OR​

1. • •The Start an Application quick link on the home page.  

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 3: Select Extreme and Uncontrollable Circumstances Exception

Select the Extreme and Uncontrollable Circumstances Exception, then click Continue.

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 4: Select Application Type

Select the participation level at which you intend (or intended) to participate in MIPS.

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 5: Enter Participation Level Information

Enter the required participation level information.

The required information for each participation level is as follows:

Participation Level	Required Information
Individual Clinician	•National Provider Identifier (NPI)  •Practice Affiliation
Group	•Taxpayer Identification Number (TIN)
Virtual Group	•Virtual Group Identifier
APM Entity	•APM Entity ID

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 6: Enter Submitter Details

Enter your contact information (as the submitter) and identify your relationship to the party identified in the application.

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 7: Enter Additional Staff in the Additional Access Section

You can identify additional users to receive notifications about the application in the Additional Access section.

If there’s a HARP account associated with the email address(es) you provide, the person will be able to sign in to their QPP Account on qpp.cms.gov and access the application.

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 8: Enter the Extreme and Uncontrollable Circumstances Event Type

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 9: Provide a Brief Description of the Challenges You Experienced

Provide a brief description about the data collection challenges that you experienced due to the extreme and uncontrollable event and how your 2022 performance data will be impacted.

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 10: Select MIPS Performance Categories

Select each MIPS performance category for which you are requesting reweighting by checking the corresponding box next to the category name, then select Submit for Review.

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Step 11: Submit Extreme and Uncontrollable Circumstances Application

Once you are done with your application, review the disclosures, then select the Submit for Review button.

 

Extreme and Uncontrollable Circumstances Application Process: Application Steps

Extreme and Uncontrollable Circumstances Exception Application Submission Confirmation

After you submit your application, you will receive a message stating that your application has been successfully submitted and is pending review. You will also receive an email notification.

 

Help, Resources, and Version History

 

Resource

2022 Automatic Extreme and Uncontrollable Circumstances Policy Fact Sheet (PDF)

2022 MIPS Promoting Interoperability Hardship Exception Application Guide (PDF)

 

Date	Description
10/06/2022	Updated deadline to request an exception to January 3, 2023, at 8 p.m. ET (slides 6 and 18)
05/02/2022	Original Posting.

 

Appendices

 

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
No Reweighting
Standard Weighting under traditional MIPS	30%	30%	15%	25%
Reweight 1 Performance Category
No Cost (Cost  Quality and Promoting Interoperability)	55%	0%	15%	30%
No Improvement Activities (Improvement Activities  Quality)	45%	30%	0%	25%
No Promoting Interoperability (Promoting Interoperability  Quality)	55%	30%	15%	0%
No Quality (Quality  Promoting Interoperability)	0%	30%	15%	55%

 

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
Reweight 2 Performance Categories
No Cost + No Promoting Interoperability (Cost + Promoting Interoperability  Quality)	85%	0%	15%	0%
No Cost + No Quality (Cost + Quality  Promoting Interoperability)	0%	0%	15%	85%
No Cost + No Improvement Activities (Cost + Improvement Activities  Promoting Interoperability + Quality)	70%	0%	0%	30%
No Promoting Interoperability + No Quality (Promoting Interoperability + Quality  Cost + Improvement Activities)	0%	50%	50%	0%
No Promoting Interoperability + No Improvement Activities (Promoting Interoperability + Improvement Activities  Quality)	70%	30%	0%	0%
No Quality + No Improvement Activities (Quality + Improvement Activities  Promoting Interoperability)	0%	30%	0%	70%

Reweight 3 Performance Categories

If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you will receive a score equal to the performance threshold regardless of any data submitted or not and receive a neutral payment adjustment.

Reweight 4 Performance Categories

If all performance categories are reweighted to 0%, you will receive a score equal to the performance threshold regardless of any data submitted or not and receive a neutral payment adjustment.

 

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
No Reweighting
Standard Weighting under traditional MIPS for small practices	30%	30%	15%	25%
Reweight 1 Performance Category
No Cost (Cost  Quality and Promoting Interoperability)	55%	0%	15%	30%
No Improvement Activities (Improvement Activities  Quality)	45%	30%	0%	25%
No Promoting Interoperability (Promoting Interoperability  Quality and Improvement Activities)	40%	30%	30%	0%
No Quality (Quality  Promoting Interoperability)	0%	30%	15%	55%

 

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
Reweight 2 Performance Categories
No Cost + No Promoting Interoperability (Cost + Promoting Interoperability  Quality and Improvement Activities)	50%	0%	50%	0%
No Cost + No Quality (Cost + Quality  Promoting Interoperability)	0%	0%	15%	85%
No Cost + No Improvement Activities (Cost + Improvement Activities  Promoting Interoperability + Quality)	70%	0%	0%	30%
No Promoting Interoperability + No Quality (Promoting Interoperability + Quality  Cost + Improvement Activities)	0%	50%	50%	0%
No Promoting Interoperability + No Improvement Activities (Promoting Interoperability + Improvement Activities  Quality)	70%	30%	0%	0%
No Quality + No Improvement Activities (Quality + Improvement Activities  Promoting Interoperability)	0%	30%	0%	70%

 

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
No Reweighting
Standard Weighting under the APP	50%	0%	20%	30%
Reweight 1 Performance Category
No Promoting Interoperability (Promoting Interoperability  Quality)	75%	0%	25%	0%
No Quality (Quality  Promoting Interoperability)	0%	0%	25%	75%
Reweight 2+ Performance Categories
If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you will receive a score equal to the performance threshold regardless of any data submitted or not and receive a neutral payment adjustment.

 

Draft in Progress	Submitted – Pending Approval	Approved / Denied	Withdrawn
You are currently working on your application and haven’t submitted it yet. Select Manage to continue working on your application.	You have successfully completed and submitted your application. Applications are reviewed in the order of which they are received.	We completed our review of your application and approved your request.	You have withdrawn your application. You can withdraw your application at any point in the process. An application can’t be reopened after being withdrawn. You’ll need to complete a new application.
		We completed our review of your application and denied your request.

 

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