The Centers for Medicare & Medicaid Services (CMS) re-opened the 2019 MIPS Extreme and Uncontrollable Circumstances Exception Application to individuals, groups, and virtual groups, including those who have already submitted data, due to the 2019 Novel Coronavirus (COVID-19) pandemic.

The submission period now extends to April 30, 2020. Any application submitted during this period that cites COVID-19 and is accepted by CMS will override any previous data submission.

The re-opened application is available to:

  • Individual clinicians who started, but are unable to complete, their data submission
  • Groups that started, but are unable to complete, their data submission; and
  • Virtual groups that are unable to start or complete their data submission.

Find the application here:

If you are a MIPS-eligible clinician and do not submit any MIPS data by April 30, 2020, you will qualify for the automatic extreme and uncontrollable circumstances policy. You will be automatically identified and will receive a neutral payment adjustment for the 2021 MIPS payment year.

When completing your application:

  • Select 1/1/2020 and 4/30/2020 as your start and end dates;
  • Indicate that you are unable to complete your 2019 performance year data submission due to the COVID-19 pandemic; and
  • Select all 4 MIPS performance categories for re-weighting

If your application is approved, all four performance categories will be re-weighted and you will receive a neutral payment adjustment for the 2021 payment year. In 2019, a practice needed 30 (out of 100) points to avoid a seven percent penalty in 2021, but there are no longer penalties. That said, there will be no incentive money available for any entity scoring between 30 and 75 MIPS points.  For those scoring 75 and above MIPS points, there will be positive adjustments available from the $500 million Exceptional Adjustment bucket.