NASS Insider

December 07, 2021

CMS to Apply MIPS Automatic Extreme and Uncontrollable Circumstances Exemption Policy

Due to the impact of the COVID-19 public health emergency (PHE) on physician practices, CMS will apply the Automatic Extreme and Uncontrollable Circumstances Exemption Policy (EUC) for the 2021 MIPS performance year. This 2021 policy change recognizes the continued challenges physicians face with providing care during the PHE and will reduce administrative burden. If a physician participates in MIPS as an individual, they don’t need to take any action to have the automatic EUC policy applied to them. CMS will automatically identify and re-weight all 4 MIPS performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless you 1) submit data in 2 or more performance categories, or 2) have a higher final score from group or APM Entity participation.  

The automatic EUC policy only applies to MIPS eligible clinicians eligible to participate as individuals, NOT to groups, virtual groups, or Alternative Payment Model (APM) entities.  

If a group practice, virtual group, or APM entity that typically participates in MIPS has not submitted 2021 data, then the automatic EUC policy will apply to the individual physicians within the group. If the group has submitted any 2021 data, then they will need to apply for the EUC to avoid a 2023 payment adjustment.  

Payment exception applications can be submitted through December 31, 2021 via