The QPP established an automatic extreme and uncontrollable circumstances (EUC) policy beginning with the 2017 performance year for clinicians affected by natural disasters. Clinicians affected by these extreme and uncontrollable circumstances may have their performance categories reweighted or receive a neutral payment adjustment. For additional information: click here.
Providers/Groups who have been impacted by COVID-19 to the point of not meeting the Performance Threshold at any point during the reporting year may apply for an Extreme & Uncontrollable Circumstance Accommodation. Providers/Groups must submit an application detailing the extent to which they were impacted by COVID-19 through the QPP portal. Providers/Groups granted this accommodation will be given a neutral payment adjustment and will not have to submit data for the 2021 Performance Year.
Recommendation from the MIPS Team at Keet
We recommend that our clients continue to collect MIPS PROS and only apply for accommodation if they do not anticipate meeting the minimum reporting threshold (60 points) requirement by December 31st, 2021. This recommendation is based on numerous reasons, the first of which is the potential for Keet clients to receive a positive payment bonus is very high, despite this COVID exemption. Another important factor is that the Medicare Fee Schedule is effectively frozen. The only way to receive an increase in reimbursement is through successful participation in MIPS or APMs. In addition, there is a potential 8% cut to Physical Therapy services in 2021. A MIPS bonus will help to neutralize the unfortunate reimbursement decrease in future years. Last, the reputational advantage of participating in MIPS will arm your practice with published data that is available to be used in marketing, contract negotiations, and provider directories.
In contrast to 2019's COVID-19 accommodations, the 2021 accommodation is individually automatically applied, however, groups need to undergo an application for reweighting. This process requires an application for each Tax Identification Number reported on by an organization. A group may also choose to submit applications for individual providers who have opted-in or are mandated to report. If an application is filled out for a group, it does cover all NPIs associated with the Group Tax ID Number.
To submit an application, you must have an HCQIS Access Roles and Profile (HARP) Account. For more details on registering for a HARP account, access the QPP Access User Guide.
In completing the application, organizations must select what categories they were unable to meet submission requirements due to the pandemic. If the application is approved, those categories will receive a 0% weighting, resulting in the other categories reported on being re-weighted to equate to 100%. You may choose to apply for accommodation in all categories, but only if you meet the criteria for the necessity of exception for all. Due to the information required on the impact of COVID-19 on your specific business, Keet is unable to complete this application on behalf of our clients.
Applications are considered on a rolling basis, and decisions are typically awarded within 14 days of application. Factors that influence approval are the event circumstances and the length of time in which you were impacted for each performance category selected in the application.
“For example, the performance period for an improvement activity is a continuous 90- day period (or as specified in the activity description) whereas the performance period for the Quality performance category is 12 months, so an issue lasting 3 months may have more impact on the availability of measures for the Quality performance category than your ability to perform and attest to improvement activities.” 2020 QPP Exception Application Fact Sheet
Keet clients whose MIPS eligible clinicians are made up of only Physical Therapists, Occupational Therapists, and Speech-Language Pathologists are automatically excepted from having to submit data for the Cost & Promoting Interoperability Performance Categories. This results in an automatic reweighting of the remaining categories to Quality category 85% and Improvement Activities 15%. No additional application is needed if you wish to continue to submit as normal on Quality & Improvement Activities.
Based on the reweighting component, If a group (or individual) has submitted a(n) application(s) that results in less than two categories eligible for scoring, they will be awarded a neutral payment adjustment for the 2021 Performance Year. Suppose a Keet client decides to submit an application for accommodation on one of the two remaining categories (quality/improvement activities), and the application is approved. In that case, the client will receive a neutral payment adjustment and will not be eligible for any positive payment adjustment earned during the 2021 Performance Year. They also will not need to submit any data for the 2021 Performance Year.
How to Submit an Application
2021 MIPS Participants can submit an Extreme and Uncontrollable Circumstances Application by following these steps:
- Register for a HARP Account (same account used to sign in to the QPP)
- Sign in to qpp.cms.gov
- Select ‘Exceptions Applications’ on the left-hand navigation
- Select ‘Add New Exception’
- Select ‘Extreme and Uncontrollable Circumstances Exception’
- Complete the application for individual, group or virtual group participation
Find more detailed instructions here, About Exception Applications
For additional information on the Extreme and Uncontrollable Circumstances Exception, check out the QPP posting here.
You can check the eligibility status of groups and providers here.
For specific questions related to eligibility or necessity of submission, contact the QPP by calling 1-866-288-8292.
For questions related to the submission of your data by Keet Health, contact firstname.lastname@example.org