On Nov. 10, the Centers for Medicare & Medicaid Services (CMS) announced that it will apply the Merit-Based Incentive Payment System (MIPS) automatic extreme and uncontrollable circumstances (EUC) policy to all individual MIPS-eligible clinicians for 2021 MIPS reporting. The policy applies only to clinicians who are eligible to participate in MIPS as individuals; it does not apply to groups, virtual groups or alternative payment model (APM) entities.
What does this mean for clinicians who are eligible to participate in MIPS as individuals?
You don’t need to take any action to have the automatic EUC policy applied to you. You will have all four MIPS performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless you 1) submit data in two or more performance categories; or 2) have a higher final score from group or APM entity participation.
What does this mean for groups?
The automatic EUC policy does not apply to groups. No further action is needed if you are not able to submit data for the 2021 performance year. Group participation is optional, and your MIPS-eligible clinicians will qualify as individuals for the automatic EUC policy if the group does not report on their behalf. If you submit data at the group level on behalf of your MIPS-eligible clinicians, the group will receive a final MIPS score based on the data submitted.
What happens if I submitted an EUC application while also qualifying for the automatic EUC policy?
For MIPS-eligible clinicians, the automatic EUC policy will supersede any performance category reweighting approved through an EUC application. For example, a MIPS-eligible clinician who qualifies for the automatic EUC policy will have all four performance categories reweighted to 0% even if they were only approved for reweighting in one or two categories through an EUC application.
You can learn more about this policy by accessing the following resources:
- Merit-Based Incentive Payment System (MIPS) Automatic Extreme and Uncontrollable Circumstances (EUC) policy
- 2021 MIPS Extreme and Uncontrollable Circumstances Application Guide
- Quality Payment Program COVID-19 Response Fact Sheet
Allison Plitman, MPA, is the communications specialist for the ACR’s RISE Registry.