CMS recently announced that it will hold physicians harmless from up to 9% MIPS penalties on physician practices’ performance in 2020 due to the COVID-19 public health emergency. The Extreme and Uncontrollable Circumstances Hardship Exception policy
will be automatically applied to ALL MIPS eligible clinicians who do not submit any MIPS data for the 2020 performance period. CMS is also reopening the hardship exception application for group practices, virtual groups, and alternative payment model entities who missed the previous 2020 deadline. The re-opened application deadline is March 31, 2021. Please note that groups and eligible clinicians who submit data in at least two MIPS categories will override the hardship exception and be eligible to earn a bonus from the exceptional performance bonus pool or potentially be subject to a penalty.