2020 QPP Extreme and Uncontrollable Circumstances Exception Application

November 20, 2020

CMS has implemented flexibilities for the Quality Payment Program (QPP) in response to the 2019 Novel Coronavirus (COVID-19) pandemic public health emergency (PHE). In this article, we discuss the 2020 QPP Extreme and Uncontrollable Circumstances Exception Application.

During 2020 practices may have experienced circumstances (e.g., COVID-19) that made it difficult to meet QPP requirements. To reduce this burden, CMS is providing an opportunity for qualifying clinicians and groups to apply for exceptions to meeting the Merit-based Incentive Payment System (MIPS) program requirements.

In order to be granted an exception from CMS (not required to report MIPS data for 2020), a practice must submit an application:

  • CMS  will be using their Extreme and Uncontrollable Circumstances policy to allow clinicians and groups to submit an application requesting reweighting of one or more MIPS performance categories.
  • For a practice to have their MIPS Quality, Cost, Improvement Activities, and/or Promoting Interoperability performance categories reweighted to 0%, they have to show that they, “Experienced an extreme and uncontrollable circumstance outside of their control, such as a natural disaster or public health emergency (e.g., COVID-19 pandemic):
    • That prevented them from collecting data for an extended period of time, or
    • That could impact performance on cost measures.”
  • The application is open through December 31, 2020 and are reviewed on a case-by-case basis.
  • If approved, the performance categories included in the application are weighted at 0% and will not contribute to the final score. It is important to note, that if any MIPS data is submitted after an application has been approved, this can void the approved application and the score given.

Additional Information:

CMS QPP COVID-19 Response website

2020 QPP Exception Application fact sheet 

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