American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

The Centers for Medicare & Medicaid Services (CMS) has extended the 2019 Merit-based Incentive Payment System (MIPS) data submission from March 31, 2020, to April 30, 2020. They are also offering additional relief for MIPS-eligible clinicians by automatically applying the Extreme and Uncontrollable Circumstances Policy for individual clinicians who do not submit MIPS data in two or more performance categories by the extended deadline of April 30, 2020. Those eligible for this will automatically receive a neutral payment adjustment in the 2021 payment year.

First, we recommend that Fellows check their participation status in the QPP Participation Look-Up Tool. This will show if you are eligible for the automatic policy.

CMS has also reposted the Extreme and Uncontrollable Circumstances application and extended the application deadline to April 30, 2020, for groups, virtual groups, or individuals who had already submitted some MIPS data, but whose data will be affected by the pandemic.

Follow these steps to submit an extreme and uncontrollable circumstances application:

  • Visit the CMS website, which has updated information about the exceptions.
  • Access the application.
  • CMS gives these instructions for completing the application:
    • Select 1/1/2020 and 4/30/2020 as your start and end dates.
    • Indicate that you are unable to complete your 2019 performance year data submission due to the COVID-19 pandemic.
    • Select all four (4) MIPS performance categories for re-weighting.
  • If the application is approved, this will override any data that was previously submitted, all four categories will be re-weighted and they will receive a neutral payment adjustment for the 2021 payment year.

To be safe, we recommend that you submit an application, even if you are eligible for the automatic extreme and uncontrollable circumstances reweighting.

For further information and assistance, contact

Resources and News

CMS COVID-19 Relief Fact Sheet

CMS to Offer MIPS Credit to Clinicians Participating in COVID-19 Clinical Trials