Eligible Clinicians Impacted by Wildfires and Hurricanes to be Exempted from MIPS Reporting for 2018 Performance Year

Eligible Clinicians Impacted by Wildfires and Hurricanes to be Exempted from MIPS Reporting for 2018 Performance Year

 

The Centers for Medicare and Medicaid Services (CMS) has established an automatic extreme and uncontrollable circumstances policy for the 2017 performance period for MIPS to reduce the burden on clinicians affected by California wildfires and Hurricanes Harvey, Irma, Maria, and Nate.

As a part of its CY 2019 Medicare Physician Fee Schedule Final Rule, CMS finalized that this automatic policy will extend to future years of MIPS, beginning with the 2018 MIPS performance period to reduce burdens for any MIPS eligible clinician in counties that the Federal Emergency Management Agency (FEMA) has designated as a disaster area by Hurricane Florence, Hurricane Michael, and the wildfires in California.  FEMA has designated the following California counties as disaster areas:  Butte, Los Angeles and Ventura counties.

The "Extreme and Uncontrollable Circumstances" policy grants MIPS-eligible clinicians exceptions without having to submit an exception request. This automatic extreme and uncontrollable circumstances policy only applies to you if you’re an individual MIPS-eligible clinician in an affected area (determined by zip code and based on information in the Provider Enrollment, Chain and Ownership System [PECOS]). The automatic extreme and uncontrollable circumstances policy does not apply to groups or virtual groups, or MIPS-eligible clinicians in alternative payment models (APM), such as the Medicare Shared Savings Program.

Under this policy, MIPS eligible clinicians who are located in a designated region that has been affected by an extreme and uncontrollable event during the 2018 MIPS performance period will not be required to submit an application to reweight the performance categories under MIPS. Physicians affected by the California wildfires will automatically receive a neutral MIPS payment adjustment, unless they submit data for two or more MIPS performance categories by the 2018 submission deadline. Under the automatic extreme and uncontrollable circumstances policy, the Cost performance category will always be weighted at 0 percent, even if you submit data for the other performance categories.

While not covered by the automatic extreme and uncontrollable circumstances policy, MIPS eligible clinicians who are subject to the APM scoring standard and identified as affected by an extreme and uncontrollable circumstance may apply for an exception in the Promoting Interoperability performance category. Groups and virtual groups can complete an extreme and uncontrollable circumstance application if the fires have impacted their ability to collect data, at a group level, for a specific MIPS performance category.

For more information read CMS’ fact sheet, “2018 MIPS Automatic Extreme and Uncontrollable Circumstances Policy,”

If you are uncertain as to whether or not you are automatically exempted under this policy for the 2018 performance period, contact the CMS QPP help desk directly at QPP@cms.hhs.gov.

CPMA/APMA members can view APMA’s resources for the 2018 performance year at www.apma.org/MIPS2018. For more information, email APMA’s Health Policy and Practice department at healthpolicy.hpp@apma.org.