Appendix I 2024 MIPS Extreme and Uncontrollable Circumstances Excep

Merit-based Incentive Payment System (MIPS)

2024 Extreme and Uncontrollable Circumstances Exception Application Guide

 

Table of Contents

How To Use This Guide        3

Overview        5

Frequently Asked Questions        14

Application Steps        18

Help and Version History        32

Appendices         35

Purpose: This guide will provide general information about the Extreme and Uncontrollable Circumstances (EUC) Exception application and provide step-by-step instructions on how to complete the application.

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How to Use This Guide

 

How to Use This Guide

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MIPS Extreme and Uncontrollable Circumstances Exception Application Overview

 

Overview

What	The MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application allows you to request reweighting for one or more performance categories to 0%. See Appendix A1, Appendix A2, and Appendix B for more information on performance category reweighting in traditional MIPS, MIPS Value Pathways (MVPs) and the APM Performance Pathway (APP).
Who	Individual clinicians, groups, virtual groups, and APM Entities. •Third party intermediaries can submit an application with permission from the clinician or practice.   Subgroups will inherit any reweighting applied to their affiliated group; they can’t request reweighting independent of their affiliated group’s status. See Slide 11 for additional information.
Why	You can submit an application to have your MIPS quality, cost, improvement activities, and/or Promoting Interoperability performance categories reweighted to 0% if: •You experience an extreme and uncontrollable circumstance outside of your control, such as a natural disaster, ransomware attack or public health emergency (PHE), that prevents you from collecting data for an extended period of time, or that could impact your performance on cost measures.   The 2019 Coronavirus (COVID-19) PHE ended on May 11, 2023. We’re not accepting applications due to COVID-19 for the 2024 performance year. Note: APM Entities are required to request reweighting for all performance categories.
When	The MIPS EUC Exception application will close at 8 p.m. ET on December 31, 2024.
Where	Sign in to the Quality Payment Program (QPP) website with your HCQIS Access and Roles Profile (HARP) account. You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide (ZIP, 3MB).  Note: APM Entity representatives must have the Security Official role in order to complete the Extreme and Uncontrollable Circumstances Exception application on behalf of their entity. Refer to the Connect to an Organization document in the QPP Access User Guide (ZIP, 3MB) for more information on requesting the Security Official role.
How	1. Register for a HARP account. 2. Sign in to the QPP website. 3. Select ‘Exceptions Applications’ on the left-hand navigation.	4. Select ‘Add New Exception.’ 5. Select ‘Extreme and Uncontrollable Circumstances Exception.’ 6. Complete the application for individual, group, virtual group, or APM Entity participation.

 

Policies for Individual Clinicians, Groups, and Virtual Groups

 

Intersection Between the Automatic MIPS EUC Policy and the Application-Based MIPS EUC Policy

Scenario

Outcome

A MIPS eligible clinician who is eligible for the automatic MIPS EUC policy has also submitted an MIPS EUC Exception application. The application was approved for reweighting in the Promoting Interoperability performance category, and the clinician submits data for the quality and improvement activities performance categories.

You’ll be scored as follows: •The quality and improvement activities performance categories will be scored because you submitted data for those categories  •The cost performance category is reweighted to 0% under the automatic EUC policy.  •The Promoting Interoperability performance category is also reweighted to 0% under the automatic EUC policy.   Note, in this example, the MIPS EUC Exception application wasn’t needed to reweight the Promoting Interoperability performance category due to the automatic MIPS EUC policy.

 

Individual Clinicians, Groups, and Virtual Groups Reporting Traditional MIPS / Individual Clinicians and Groups Reporting an MVP

Scenario

Outcome

You’re planning to report traditional MIPS or registered to report an MVP. You submit an application to have all 4 performance categories reweighted to 0%, but later determine you’re able to report the improvement activities and Promoting Interoperability performance categories.

You’ll receive a MIPS final score based on the data submitted. •The improvement activities performance category will be weighted at 15%.  •The Promoting Interoperability performance category will be weighted at 85%.   •The quality performance category will retain a 0% weight because you didn’t submit quality data.   •The cost performance category will retain a 0% weight because there are no data submission requirements associated with the cost performance category (reweighting can’t be voided).

 

Individual Clinicians and Groups Reporting the APP

Scenario

Outcome

You’re a MIPS eligible clinician (or group) planning to report the APP. You submit an application to reweight the quality performance category and your application was approved.

You’ll receive a MIPS final score based on the data submitted. •The improvement activities performance category will be weighted to 25%.   •The Promoting Interoperability performance category will be weighted to 75%.   •The quality performance category will be weighted at 0% provided no data is submitted.   •The cost performance category will retain a 0% weight (because cost isn’t scored under the APP).

 

Policies for Subgroups Reporting an MVP

Clinicians who register to report an MVP as a subgroup will inherit the performance category reweighting approved for their affiliated group.

• •Data submission by the affiliated group won’t override performance category reweighting for the subgroup. 

• •Data submission by the subgroup won’t override performance category reweighting for the affiliated group, it will only override performance category reweighting for the subgroup. 

1. • • •Subgroups can’t submit a MIPS EUC Exception application as outlined in this guide. 

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Policies for APM Entities

Scenario

APM Entities in the following models can submit an EUC Exception application on behalf of their MIPS eligible clinicians:

• • •ACO Realizing Equity Access and Community Health (ACO REACH) 

  • •Advancing All-Payer Health Equity Approaches and Development (AHEAD) Model* 

  • •Bundled Payments for Care Improvement (BPCI) Advanced Model 

  • •Comprehensive Care for Joint Replacement (CJR) Payment Model 

  • •Enhancing Oncology Model (EOM) 

  • •Guiding an Improved Dementia Experience (GUIDE) Model 

  • •Kidney Care Choices (KCC) 

  • •Making Care Primary (MCP) 

  • •Maryland Total Cost of Care Model 

  • •Medicare Shared Savings Program  

  • •Primary Care First (PCF) 

  • •States AHEAD Model - Hospital Track* 

  • •Value in Opioid Use Disorder Treatment (ViT) 

  • •Vermont Medicare ACO Model  

 

Policies for APM Entities (Continued)

APM Entity applications must be submitted for all performance categories.

1. • • •You can’t submit an application to request reweighting in 1 or 2 performance categories. 

     • •This is different from our policy for individual, group, and virtual group applications. 

If your APM Entity’s application is approved, the APM Entity will receive a final score equal to the performance threshold even if data are submitted for the APM Entity.

1. • • •The MIPS eligible clinicians in the APM Entity will receive a neutral MIPS payment adjustment unless they have a higher final score from individual or group participation. 

     • •Data submitted for an APM Entity will not override performance category reweighting from an approved application.  

     • •This is different from our policy for individual, group, and virtual group applications.  

At least 75% of MIPS eligible clinicians in an APM Entity must qualify for reweighting of the Promoting Interoperability performance category.

1. • • •Given that APM Entities are required to request reweighting for all performance categories in their EUC Exception application, at least 75% of the MIPS eligible clinicians in the Entity will need to qualify for reweighting in the Promoting Interoperability performance category. 

     • •They may qualify automatically or by meeting one of the reasons identified in the MIPS Promoting Interoperability Hardship Exception Application. 

APM Entity representatives must have a QPP Security Official role to complete the Extreme and Uncontrollable Circumstances Exception application on behalf of their entity.

• •Review the Connect to an Organization resource in the QPP Access User Guide (ZIP, 3MB) for more information on obtaining the Security Official role. 

An approved application won’t affect your model-specific reporting requirements.

1. • • •For example, Shared Savings Program ACOs must report the quality measures identified in the APP to meet Shared Savings Program requirements, unless otherwise excepted. 

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MIPS Extreme and Uncontrollable Circumstances Exception Application Process: Frequently Asked Questions

 

How Does CMS Assess MIPS EUC Exception Applications?

We consider the variables affecting your ability to collect and submit data for each performance category when reviewing your application for performance category reweighting due to extreme and uncontrollable circumstances.

During our review, we will review both the event circumstances and the length of time you were impacted as indicated in your application to assess your ability to submit data for each performance category selected in the application.

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Are We Required to Submit Documentation with Our EUC Exception Application?

• •No, you aren’t required to submit documentation with your application.  

• •However, you should retain documentation of the circumstances supporting your application for your own records in the event that you are selected by CMS for data validation or an audit. See our 2024 MIPS Data Validation Criteria Guide (ZIP, 2MB) for information on the data validation and audit process.  

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Can We Submit one MIPS EUC Exception Application at the Group Level rather than Separate Applications for Each Individually Eligible Clinician?

• •Yes, you can submit a group-level application instead of separate applications for each clinician if the EUC applies to the whole group. However, if the circumstances are specific to a subset of clinicians in the group, you’d need to submit individual applications for each of those clinicians. 

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MIPS Extreme and Uncontrollable Circumstances Exception Application Process: Application Steps

 

Step 1: Sign in to Your QPP Account

With your HARP credentials, sign in to your QPP Account on the QPP website.

 

Step 2: Navigate to Your Exception Applications

Once you’re signed into your account, select:​

1. • •The Exception Application tab in the left-hand navigation menu, then click + Add New QPP Exception​ 

OR​

1. • •The Start an Application quick link on the home page.  

 

Step 3: Select Extreme and Uncontrollable Circumstances Exception

Select the Extreme and Uncontrollable Circumstances Exception, then click Continue.

 

Step 4: Select Application Type

Select the participation level at which you intend (or intended) to participate in MIPS, then select Save & Continue.

 

Step 5: Enter Participation Level Information

Enter the required participation level information.

The required information for each participation level is as follows:

 

Step 6: Enter Submitter Details

Enter your contact information (as the submitter) and identify your relationship to the party identified in the application.

 

Step 7: Enter Additional Staff in the Additional Access Section

You can identify additional users to receive notifications about the application in the Additional Access section.

If there’s a HARP account associated with the email address(es) you provide, the person will be able to sign in to their QPP Account on the QPP website and access the application.

 

Step 8: Enter the Extreme and Uncontrollable Circumstances Event Type

Select the appropriate Event Type for the extreme and uncontrollable circumstance you experienced.

Then, enter the timeframe for which you were impacted by the extreme and uncontrollable event by completing the Event Date Range. If you continue to be impacted by the event, select Event Still Persists.

 

Step 8: Enter the Extreme and Uncontrollable Circumstances Event Type (Continued)

Applications due to the Change Healthcare Cyberattack in late February should include “Ransom/Malware” as the Event Type. Once selected, confirm that the ransom/malware event pertained to the Change Healthcare Cyberattack.

 

Step 9: Provide a Brief Description of the Challenges You Experienced

Provide a brief description about the data collection challenges that you experienced due to the extreme and uncontrollable event and how your 2024 performance data will be impacted. 

 

Step 10: Select MIPS Performance Categories

Select each MIPS performance category for which you’re requesting reweighting by checking the corresponding box next to the category name, then select Submit for Review.

 

Step 11: Submit Extreme and Uncontrollable Circumstances Application

Once you’re done with your application, review the disclosures, then select the Certify & Submit button.

 

Step 11: Submit Extreme and Uncontrollable Circumstances Application

After you submit your application, you’ll receive a message stating that your application has been successfully submitted and is pending review. You’ll also receive an email notification.

 

Help and Version History

 

 

Version History

If we need to update this document, changes will be identified here.

DATE	DESCRIPTION
08/28/2024	Added OMB control number and expiration date on slide 1 and updated PRA disclosure language on slide 34.
06/25/2024	Updated to include PRA disclosure language.
05/13/2024	Original Posting.

 

Appendices

 

Appendix A1. 2024 Performance Year MIPS Performance Category Weight Redistribution Policies for Individual Clinicians, Groups, Virtual Groups, and APM Entities Reporting Traditional MIPS or MVPs

The table below illustrates the 2024 performance category weights and reweighting policies that CMS will apply to clinicians, groups, and virtual groups reporting traditional MIPS or MVPs. (Small practices should refer to Appendix A2.)

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
No Reweighting
Standard Weighting under traditional MIPS	30%	30%	15%	25%
Reweight 1 Performance Category
No Cost (Cost  Quality and Promoting Interoperability)	55%	0%	15%	30%
No Improvement Activities (Improvement Activities  Quality)	45%	30%	0%	25%
No Promoting Interoperability (Promoting Interoperability  Quality)	55%	30%	15%	0%
No Quality (Quality  Promoting Interoperability)	0%	30%	15%	55%

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Appendix A1. 2024 Performance Year MIPS Performance Category Weight Redistribution Policies for Individual Clinicians, Groups, Virtual Groups, and APM Entities Reporting Traditional MIPS or MVPs (Continued)

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
Reweight 2 Performance Categories
No Cost + No Promoting Interoperability (Cost + Promoting Interoperability  Quality)	85%	0%	15%	0%
No Cost + No Quality (Cost + Quality  Promoting Interoperability)	0%	0%	15%	85%
No Cost + No Improvement Activities (Cost + Improvement Activities  Promoting Interoperability + Quality)	70%	0%	0%	30%
No Promoting Interoperability + No Quality (Promoting Interoperability + Quality  Cost + Improvement Activities)	0%	50%	50%	0%
No Promoting Interoperability + No Improvement Activities (Promoting Interoperability + Improvement Activities  Quality)	70%	30%	0%	0%
No Quality + No Improvement Activities (Quality + Improvement Activities  Promoting Interoperability)	0%	30%	0%	70%
Reweight 3 Performance Categories
If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you’ll receive a score equal to the performance threshold regardless of any data submitted and you’ll receive a neutral payment adjustment.
Reweight 4 Performance Categories
If all performance categories are reweighted to 0%, you’ll receive a score equal to the performance threshold regardless of any data submitted and you’ll receive a neutral payment adjustment.

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Appendix A2. MIPS Performance Category Weight Redistribution Policies Under Traditional MIPS Finalized for the 2024 Performance Year: Small Practices

The table below illustrates the 2024 performance category weights and reweighting policies that CMS will apply to small practices. 

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
No Reweighting
Standard Weighting under traditional MIPS for small practices	30%	30%	15%	25%
Reweight 1 Performance Category
No Cost (Cost  Quality and Promoting Interoperability)	55%	0%	15%	30%
No Improvement Activities (Improvement Activities  Quality)	45%	30%	0%	25%
No Promoting Interoperability (Promoting Interoperability  Quality and Improvement Activities)	40%	30%	30%	0%
No Quality (Quality  Promoting Interoperability)	0%	30%	15%	55%

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Appendix A2. MIPS Performance Category Weight Redistribution Policies Under Traditional MIPS Finalized for the 2024 Performance Year: Small Practices

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
Reweight 2 Performance Categories
No Cost + No Promoting Interoperability (Cost + Promoting Interoperability  Quality and Improvement Activities)	50%	0%	50%	0%
No Cost + No Quality (Cost + Quality  Promoting Interoperability)	0%	0%	15%	85%
No Cost + No Improvement Activities (Cost + Improvement Activities  Promoting Interoperability + Quality)	70%	0%	0%	30%
No Promoting Interoperability + No Quality (Promoting Interoperability + Quality  Cost + Improvement Activities)	0%	50%	50%	0%
No Promoting Interoperability + No Improvement Activities (Promoting Interoperability + Improvement Activities  Quality)	70%	30%	0%	0%
No Quality + No Improvement Activities (Quality + Improvement Activities  Promoting Interoperability)	0%	30%	0%	70%

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Appendix B. 2024 Performance Year MIPS Performance Category Weight Redistribution Policies for APM Entities and APM Participants Reporting the APP 

The table below illustrates the 2024 performance category weights and reweighting policies that CMS will apply to APM Entities reporting traditional MIPS or MVPs and to individual clinicians, groups and APM Entities reporting via the APP. 

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
No Reweighting
Standard Weighting under the APP	50%	0%	20%	30%
Reweight 1 Performance Category
No Promoting Interoperability (Promoting Interoperability  Quality)	75%	0%	25%	0%
No Quality (Quality  Promoting Interoperability)	0%	0%	25%	75%
Reweight 2+ Performance Categories
If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you’ll receive a score equal to the performance threshold regardless of any data submitted and you’ll receive a neutral payment adjustment.

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Appendix C. MIPS Extreme and Uncontrollable Circumstances Exception Application Status Descriptions

Draft in Progress	Submitted – Pending Approval	Approved / Denied	Withdrawn
You’re currently working on your application and haven’t submitted it yet. Select Manage to continue working on your application.	You’ve successfully completed and submitted your application. Applications are reviewed in the order of which they’re received.	We completed our review of your application and approved your request.	You’ve withdrawn your application. You can withdraw your application at any point in the process. An application can’t be reopened after being withdrawn. You’ll need to complete a new application.
		We completed our review of your application and denied your request.

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