The Centers for Medicare & Medicaid Services (CMS) reopened the Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances (EUC) Exception Application for 2023 due to the Change Healthcare cyberattack. Clinicians who have not yet submitted their 2023 MIPS data to CMS, can submit hardship exemption requests for one or more performance categories until April 15, 2024, at 8 p.m. ET.
The Change Healthcare cyberattack must be listed as the reason for requesting the exception. Applications submitted for any other reason will be denied. For individual MIPS-eligible clinicians, groups, and virtual groups, reporting any MIPS data in any performance category to CMS will override an EUC application in that performance category.
Who can submit a 2023 MIPS EUC exception application?
Individual MIPS eligible clinicians, groups, virtual groups, and Alternative Payment Model (APM) Entities participating in MIPS (including Shared Savings Program Accountable Care Organizations) who anticipate being unable to submit data or complete their data submission for the 2023 performance year before the extended deadline because of the Change Healthcare cyberattack. Applicants can request reweighting for any or all MIPS performance categories.
Already submitted data?
In accordance with MIPS EUC policies for individuals, groups, and virtual groups, CMS will not reweight any performance category for which it has received data. If three of the performance categories are reweighted to 0% and only one performance category can be scored, then the MIPS eligible clinician, group, or virtual group will earn a final score equal to the performance threshold and receive a neutral payment adjustment.
In accordance with the MIPS EUC policies for APM Entities, data submission from an APM Entity won’t override performance category reweighting. If approved for an exception, the MIPS eligible clinicians in the APM Entity will receive a score equal to the performance threshold and a neutral payment adjustment unless the clinicians had a higher final score (for the same Taxpayer Identification Number and National Provider Identifier combination) from individual or group participation in MIPS.
How to apply:
- Sign in to the QPP website.
- Select ‘Exceptions Applications’ on the left-hand navigation
- Select ‘Add New Exception’
- Select ‘Extreme and Uncontrollable Circumstances Exception’
- Complete the application
- You MUST select “Ransom/Malware” as the Event Type and include “Change Healthcare cyberattack” in the Event Description
- Reminder: Any applications submitted for reasons outside of the Change Healthcare cyberattack will be denied
Applications are reviewed and processed on a rolling basis.
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