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In Performance Year (PY) 2021, the Centers for Medicare and Medicaid Services (CMS) have applied an automatic Extreme and Uncontrollable Circumstance (EUC) policy for the Merit-based Incentive Payment System (MIPS) to all MIPS-eligible individual clinicians. This policy was first instituted in PY 2020 to account for the health care disruptions caused by the COVID-19 pandemic.
Through this policy, individual clinicians will only be scored on performance categories they report. If no MIPS data is reported by the March 31, 2022 deadline, a neutral payment adjustment will be applied for the 2023 MIPS Payment Year. No action is required to receive EUC weighting for individual clinicians unless the individual clinician has already submitted data to CMS or a third-party intermediary for the 2021 performance year. If data was submitted prior to the March 31, 2022 deadline then the individual clinician must notify the third-party intermediary of this information.
The EUC will not be automatically applied for clinicians participating in MIPS as part of a group, virtual group, or Alternative Payment Model (APM) entity. Clinicians in this category can submit an application to request the reweighting of performance categories to 0% for PY 2021. These submissions are due on December 31, 2021. Sign into your account on the Quality Payment Program (QPP) website to view whether you are MIPS-eligible as an individual or as a group.
For more information on MIPS, visit ASA’s resource web page or CMS’ overview of MIPS participation options.
To learn more about how CMS adjusted QPP in response to the COVID-19 pandemic, click here.
Please contact the Anesthesia Quality Institute at [email protected] or the ASA Department of Quality and Regulatory Affairs at [email protected] with any further questions.
