The Centers for Medicare and Medicaid Services (CMS) announced on Thursday, Feb. 25, that groups and individuals eligible for the Merit-based Incentive Payment System (MIPS) are allowed automatic exemption from the program if they do not submit data for the 2020 performance year. CMS also reopened the Extreme and Uncontrollable Circumstances (EUC) application through Mar. 31, 2021.
Whether practices are automatically exempt from MIPS participation in 2020 or whether an application is required to request exemption depends on practices’ MIPS participation status and the amount of data submitted to CMS for MIPS for 2020 participation. Individual submitters who have yet to submit data or submit data for one performance category (e.g., Quality, Improvement Activities or Promoting Interoperability) to CMS are automatically exempt from the MIPS payment adjustment and will receive neutral payment in 2022. Individuals who already submitted data to CMS for two or more MIPS categories are not eligible for exemption.
Group submitters that do not submit data to CMS for MIPS 2020 are also automatically exempt. However, if data was already submitted for one performance category, an application is required to receive an exemption under the EUC exception. Groups with data already submitted for two or more performance categories are ineligible for exemption and subject to payment adjustments in 2022.
Virtual groups that do not submit data must apply to CMS for an EUC exception before the March 31, 2021 deadline to receive a neutral payment in 2022.
For more information, see the 2020 MIPS Automatic Extreme and Uncontrollable Circumstances Policy fact sheet.