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MIPS and the Public Health Emergency

For the 2020 performance year, CMS will be using its Extreme and Uncontrollable Circumstances policy to allow clinicians and groups to submit an application requesting reweighting of one or more Merit-based Incentive Payment System (MIPS) performance categories due to the current COVID-19 public health emergency. Suggested next steps:

  • Check your MIPS eligibility status. If you are eligible (and hence subject to a payment adjustment) and feel the public health emergency has impacted your ability to report, consider applying for an Extreme and Uncontrollable Circumstance exception.
  • Learn more about this policy and access the exception application here.
    • This exception is applied via the eligible clinician or designee’s HARP account at qpp.cms.gov. COVID-19 is a pre-set reason that can be selected.
    • The application must be submitted to CMS no later than February 1, 2021.
  • If you plan to report to MIPS for the 2020 performance year, note the following dates and keep in mind third-party vendors may have deadlines well in advance of these noted below.
    • January 4, 2021 - 2020 MIPS data submission window opens.
    • March 1, 2021 – Deadline for CMS to receive 2020 claims for the Quality performance category. Claims must be received by CMS within 60 days of the end of the performance period. Deadline dates vary to submit claims to the MACs. Check with the MACs for more specific instructions.
    • March 31, 2021 – 2020 MIPS performance year data submission window closes.