In response to ASCP advocacy, CMS announced on Feb. 25 that physicians will be held harmless from MIPS penalties due to the ongoing COVID-19 pandemic. The MIPS automatic extreme and uncontrollable circumstances (EUC) policy applies to all MIPS eligible clinicians for the 2020 performance period, and holds physicians harmless from up to a 9% MIPS payment penalty in 2022. This policy is automatically applied to all MIPS eligible clinicians who do not submit MIPS data for the 2020 performance period.
Additionally, CMS is reopening the MIPS EUC application for groups, virtual groups, and Alternative Payment Model Entities who missed the previous deadline last year. The application is reopened until March 31, 2021 at 8 p.m. ET. Individual MIPS eligible clinicians and groups who have not submitted any data for 2020 will not need to submit an application or take any additional action to qualify for the automatic EUC policy. If groups and eligible clinicians have already submitted data for 2020 in at least two MIPS performance categories, the EUC application will not override the data submission, and those groups and clinicians will be eligible for a bonus or a penalty based on the data submitted.
Clinicians in a virtual group who are unable to submit data for the 2020 performance year must submit an EUC application for all of the MIPS performance categories by the March 31 deadline.
APM Entities submitting an EUC application are required to request reweighting for all performance categories, and more than 75% of the MIPS eligible clinicians in the APM Entity must be eligible for reweighting in the Promoting Interoperability category. Unlike the applications for individuals, groups, and virtual groups, an APM Entity’s approved EUC application will override previously submitted data.
ASCP is pleased that CMS has implemented this policy to provide relief to clinicians. We will continue to advocate on behalf of our membership for meaningful, impactful changes that improve quality of care and reduce burden. Find one of ASCP’s letter urging CMS to provide relief from the MIPS penalties
here.
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For more information regarding ASCP's advocacy initiatives and policy positions, please contact ASCP's Center for Public Policy at (202) 408-1110.
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