CMS to hold physicians harmless from 2023 MIPS penalties amid COVID-19 pandemic

November 16, 2021

The Centers for Medicare and Medicaid Services (CMS) recently announced that it will again this year be granting automatic exceptions from reporting requirements for clinicians and providers participating in Medicare quality reporting programs due to the ongoing disruptions the COVID-19 public health emergency is having on physician practices.

The Extreme and Uncontrollable Circumstances (EUC) Hardship Exception policy will be automatically applied to all MIPS eligible clinicians who do not submit any MIPS data for the 2021 performance period (2023 payment year). Physicians who haven’t submitted any MIPS data do not need to take any additional action to qualify for the automatic EUC policy. CMS will automatically identify and re-weight all 4 MIPS performance categories to 0% and apply a neutral payment adjustment for the 2023 MIPS payment year.

Unfortunately, if a physician or small practice has submitted quality data codes on their 2021 Medicare claims, they will need to still file a 2021 MIPS Hardship EUC to avoid a 2023 payment adjustment and be exempt from the 2021 MIPS program.

If a group practice that typically participates in MIPS as a group 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.

Essentially, if the physician or practice has not submitted any 2021 MIPS performance data, then the automatic EUC will apply to the physician.

PY2021 EUC Exception Applications can be submitted by signing in to qpp.cms.gov and clicking Exception Applications on the left-hand navigation.

For more detailed information on the automatic EUC policy and CMS announcement, click here.


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