Appendix I 2022 MIPS Extreme and Uncontrollable Circumstances Excep

Quality Payment Program (QPP)/Merit-Based Incentive Payment System (MIPS) (CMS-10621)

Appendix I 2022 Extreme and Uncontrollable Circumstances Exception Application Guide.pptx

OMB: 0938-1314

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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

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.

- - •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.

- - •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 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.

- - •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.

- - •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.

- - •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.

- - •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

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.