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

Updated Extreme and Uncontrollable Circumstances Exceptions (EUC) for 2020 QPP Performance

Last week, the Centers for Medicare & Medicaid Services (CMS) announced that they will apply the Merit-based Incentive Payment System (MIPS) automatic extreme and uncontrollable circumstances (EUC) policy to certain individual MIPS-eligible clinicians for the 2020 performance period to offer flexibilities for clinicians responding to the Coronavirus Disease 2019 (COVID-19) pandemic. CMS will also reopen the MIPS EUC Application for individual MIPS-eligible clinicians, groups, virtual groups, and Alternative Payment Model (APM) entities through March 31, 2021. If you have already submitted MIPS data for the 2020 performance period, applications received between now and March 31, 2021, will not override previously submitted data.

  • Individual clinicians who have not submitted data or submitted data for only one performance category do not need to take any additional action to qualify for the automatic EUC policy. In this case, all four MIPS performance categories—quality, improvement activities, promoting interoperability, and cost—will be reweighted to 0 percent and the clinician will receive a neutral payment adjustment for the 2022 MIPS payment year. However, note that this automatic MIPS exemption will not apply if the clinician submits data in two or more performance categories as an individual, or if the clinician’s practice reports as a group by submitting data for one or more performance categories.  
    • Individuals who have submitted data for two or three performance categories will receive a MIPS final score and payment adjustment for the 2022 payment year based on the data submitted. EUC applications do not override previously submitted data.
    • Individuals in a group practice who submitted data will receive the group’s final score and associated payment adjustment unless they have a higher score from individual participation. 
  • Groups that haven’t submitted data for the 2020 performance period and are unable to do so do not need to take any further action. Group participation is optional and the individual MIPS-eligible clinicians in the group qualify for the automatic EUC policy and will receive a neutral payment adjustment in 2022 so long as they have not submitted data in two or more categories. 
  • Virtual Groups unable to submit data for the 2020 performance period must submit an EUC application for all four performance categories by the March 31, 2021, deadline to receive the neutral adjustment.
  • Practices that report as a Group and Virtual Groups that have submitted data for a single performance category can submit an EUC application to request reweighting in all four performance categories if they are unable to complete the data submission for the other performance categories. If the application is approved and data is not submitted for another MIPS performance category, the MIPS-eligible clinicians in the group will receive a neutral payment adjustment for the 2022 payment year. If the group does not submit an application, the group will be scored in all performance categories unless it is eligible for reweighting in one or more performance categories. 
  • Groups and Virtual Groups that have submitted data for two or three performance categories will receive a MIPS final score and payment adjustment for the 2022 payment year based on the data that was submitted. EUC applications do not override previously submitted data.
  • APM Entities participating in MIPS APMs are required to submit an EUC application and request reweighting for all performance categories, and more than 75% of the clinicians in the APM entity must be eligible for reweighting in the Promoting Interoperability category. Please note: That an APM Entity’s approved EUC application will override previously submitted data. If the APM entity does not report for the 2020 performance and does not have an approved EUC application, the participating clinicians will receive a negative payment adjustment in the 2022 payment year.

CMS offers 2020 MIPS Extreme and Uncontrollable Circumstances Application Resources and a Quality Payment Program COVID-19 Response fact sheet to assist physicians in submitting EUC policy applications. Further questions or concerns can be directed to QualityDC@facs.org