Appendix I1 2024 MIPS Extreme and Uncontrollable Circumstances Excep

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

Appendix I1 2024 MIPS Extreme and Uncontrollable Circumstances Exception Application Guide

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Merit-based
Incentive
Payment System
(MIPS)
2024 Extreme and Uncontrollable
Circumstances Exception Application
Guide

Table of Contents
How To Use This Guide

Overview

Frequently Asked Questions

Application Steps

Help and Version History

Appendices

Purpose: This guide will provide
general information about the
Extreme and Uncontrollable
Circumstances (EUC) Exception
application and provide step-by-step
instructions on how to complete the
application.

Already know what MIPS is? Skip
ahead by clicking the links in the Table
of Contents.

How to Use This
Guide

OVERVIEW

How to Use This Guide

Table of Contents
Please Note: This guide was prepared for
informational purposes only and isn’t intended
to grant rights or impose obligations. The
information provided is only intended to be a
general summary. It isn’t intended to take the
place of the written law, including the
regulations. We encourage readers to review the
specific statutes, regulations, and other
interpretive materials for a full and accurate
statement of their contents.

The Table of Contents is interactive. Click on a
Chapter in the Table of Contents to read that
section.
You can also click on the icon on
the bottom left to go back to the Table of
Contents.
Hyperlinks
Hyperlinks to the Quality Payment Program
website are included throughout the guide to
direct the reader to more information and
resources.

MIPS Extreme and
Uncontrollable
Circumstances
Exception Application
Overview
5

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
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 clinicians, groups, virtual groups and Alternative Payment Model (APM) Entities to apply and
request performance category reweighting for MIPS.
The MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application allows you to request reweighting for one or more performance categories to 0%.

What

Who

Why

See Appendix A1, Appendix A2, and Appendix B for more information on performance category reweighting in traditional MIPS, MIPS Value Pathways (MVPs) and
the APM Performance Pathway (APP).
Individual clinicians, groups, virtual groups, and APM Entities.
• Third party intermediaries can submit an application with permission from the clinician or practice.
Subgroups will inherit any reweighting applied to their affiliated group; they can’t request reweighting independent of their affiliated group’s status. See Slide 11 for
additional information.
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), that prevents you from collecting data for an extended period of time, or that could impact your performance on cost measures.
The 2019 Coronavirus (COVID-19) PHE ended on May 11, 2023. We’re not accepting applications due to COVID-19 for the 2024 performance year.
Note: APM Entities are required to request reweighting for all performance categories.

When

The MIPS EUC Exception application will close at 8 p.m. ET on December 31, 2024.
Sign in to the Quality Payment Program (QPP) website with your HCQIS Access and Roles Profile (HARP) account.

Where

How

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, 3MB).
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, 3MB) for more information on requesting the Security
Official role.
4. Select ‘Add New Exception.’
1. Register for a HARP account.
5. Select ‘Extreme and Uncontrollable Circumstances Exception.’
2. Sign in to the QPP website.
6. Complete the application for individual, group, virtual group, or APM Entity
3. Select ‘Exceptions Applications’ on the left-hand navigation.
participation.

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Policies for Individual Clinicians, Groups, and Virtual Groups
MIPS EUC Exception applications can be submitted for
one or more performance categories. Any data you, or
someone on your behalf, submits will override approved
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 your
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 2024 MIPS performance period would be
equal to the performance threshold and you would
receive a neutral payment adjustment in 2026.

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 2024 MIPS
performance period would be equal to the performance
threshold and you would receive a neutral payment
adjustment in 2026.
You’ll be scored in any performance category that’s not included in
your application, unless you qualify for reweighting through another
policy.
For example:
• If you don’t meet the case minimum for any cost measures, the
cost performance category will be reweighted.
• You qualify for reweighting under the automatic Extreme and
Controllable Circumstances policy.
o Review the 2024 Automatic Extreme and Uncontrollable
Circumstances Fact Sheet (PDF, 225KB) for additional
information.
• Certain clinician types and individuals, groups, and virtual groups
with certain special statuses qualify for automatic reweighting of
the Promoting Interoperability performance category.
o For additional information on automatic reweighting of
Promoting Interoperability, review the 2024 Promoting
Interoperability Quick Start Guide (PDF, 1 MB).

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

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

Example
Scenario

Outcome
You’ll be scored as follows:

A MIPS eligible clinician who is eligible for the automatic
MIPS EUC policy has also submitted an MIPS 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.

• 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 MIPS EUC Exception
application wasn’t needed to reweight the Promoting
Interoperability performance category due to the
automatic MIPS EUC policy.

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Individual Clinicians, Groups, and Virtual Groups Reporting Traditional
MIPS / Individual Clinicians and Groups Reporting an MVP
If you qualify for reweighting under the automatic MIPS EUC policy, then we’ll reweight all 4 performance categories to 0% (rather
than just the categories included in your MIPS EUC Exception application). We’ll score any performance category for which data is
submitted.

Example
Scenario

Outcome
You’ll receive a MIPS final score based on the data
submitted.

You’re planning to report traditional MIPS or registered to
report an MVP. You submit an application to have all 4
performance categories reweighted to 0%, but later
determine you’re able to report the improvement
activities and Promoting Interoperability performance
categories.

• 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).

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Individual Clinicians and Groups Reporting the APP
Example
Scenario

Outcome
You’ll receive a MIPS final score based on the data
submitted.

• The improvement activities performance category will
You’re a MIPS eligible clinician (or group) planning to
be weighted to 25%.
report the APP. You submit an application to reweight the • The Promoting Interoperability performance category
quality performance category and your application was
will be weighted to 75%.
approved.
• 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).

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Policies for Subgroups Reporting an MVP
Clinicians who register to report an MVP as a subgroup will inherit the performance category reweighting approved for their
affiliated group.
• Data submission by the affiliated group won’t override performance category reweighting for the subgroup.
• Data submission by the subgroup won’t override performance category reweighting for the affiliated group, it will only
override performance category reweighting for the subgroup.
• Subgroups can’t submit a MIPS EUC Exception application as outlined in this guide.

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Policies for APM Entities
Scenario
APM Entities in the following models can submit an EUC Exception application on behalf of their MIPS eligible
clinicians:
•
•
•
•
•
•
•
•
•
•
•
•
•
•

ACO Realizing Equity Access and Community Health (ACO REACH)
Advancing All-Payer Health Equity Approaches and Development (AHEAD) Model*
Bundled Payments for Care Improvement (BPCI) Advanced Model
Comprehensive Care for Joint Replacement (CJR) Payment Model
Enhancing Oncology Model (EOM)
Guiding an Improved Dementia Experience (GUIDE) Model
Kidney Care Choices (KCC)
Making Care Primary (MCP)
Maryland Total Cost of Care Model
Medicare Shared Savings Program
Primary Care First (PCF)
States AHEAD Model - Hospital Track*
Value in Opioid Use Disorder Treatment (ViT)
Vermont Medicare ACO Model

*State-by-state determination.

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Policies for APM Entities (Continued)
APM Entity applications must be submitted for all performance categories.
• You can’t submit an application 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 Exception 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 reasons identified in the MIPS Promoting Interoperability Hardship
Exception Application.
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, 3MB) 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 in the APP to meet Shared Savings
Program requirements, unless otherwise excepted.

MIPS Extreme and
Uncontrollable
Circumstances
Exception Application
Process: Frequently
Asked Questions
14

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: FREQUENTLY ASKED QUESTIONS

How Does CMS Assess MIPS EUC Exception Applications?
We consider the variables affecting your ability to collect and
submit data for each performance category when reviewing
your application for performance category reweighting due to
extreme and uncontrollable circumstances.
During our review, we will review both the event
circumstances and the length of time you were impacted as
indicated in your application to assess your ability to submit
data for each performance category selected in the
application.

Example:
The performance period for an improvement activity is a
continuous 90-day period (or as specified in the activity
description) whereas the performance period for the quality
performance category is 12 months. An issue lasting 3 months
may have more impact on the availability of measures for the
quality performance category than your ability to perform and
attest to improvement activities.

How Long Does it Take to Process an EUC Exception Application?
The length of time it takes to process applications depends on the volume of applications we receive. We review all applications in
the order that they were received. Once a decision is made regarding your application, you’ll receive a notice of our decision and
the status of your application will be reflected in your QPP Account on the QPP website.

Where Can I Look for a Status Update on My EUC Exception
Application?
You can monitor your application status in your QPP Account on the QPP website.

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: FREQUENTLY ASKED QUESTIONS

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 2024 MIPS Data Validation Criteria Guide (ZIP, 2MB) 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 application, please contact the Quality Payment Program Service Center by email at
[email protected], by creating a QPP Service Center ticket, or by phone at 1-866-288-8292 (Monday-Friday, 8 a.m. - 8 p.m.
ET).

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 you
would like to receive email notifications.
• Please note that the additional staff or representatives must have HARP credentials to see the application on the QPP website.

Important Note: Corrections can’t be made after the application period has closed.

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: FREQUENTLY ASKED QUESTIONS

Can We Submit one MIPS EUC Exception Application at the Group Level
rather than Separate Applications for Each Individually Eligible Clinician?
• Yes, you can submit a group-level application instead of separate applications for each clinician if the EUC applies to the whole
group. However, if the circumstances are specific to a subset of clinicians in the group, you’d need to submit individual
applications for each of those clinicians.

Our Third Party Intermediary Experienced Issues and Is Unable to Submit Data
on Our Behalf. Can We Submit an EUC Exception Application for this Issue?
• As noted in the Calendar Year 2018 Quality Payment Program Final Rule, extreme and uncontrollable circumstances, such as
natural disasters, may affect a clinician's ability to access or submit quality measures via all submission mechanisms (effectively
rendering the measures unavailable to the clinician), as well as the availability of numerous improvement activities. In addition,
damage to a facility where care is provided due to a natural disaster, such as a hurricane, could result in practice management
and clinical systems that are used for the collection or submission of data to be down, thus impacting a clinician's ability to
submit necessary information via Qualified Registry, QCDR, CMS Web Interface, or claims.
• This policy doesn’t include issues that third party intermediaries, such as Electronic Health Record vendors (EHRs), QCDRs, or
Qualified Registries, might have submitting information to MIPS on behalf of a MIPS eligible clinician.

• Instead, this policy is geared towards events, such as natural disasters, that affect the MIPS eligible clinician's ability to submit
data to the third party intermediary, which in turn, could affect the ability of the clinician (or the third party intermediary
acting on their behalf) to successfully submit measures and activities to MIPS.

MIPS Extreme and
Uncontrollable
Circumstances
Exception Application
Process: Application
Steps
18