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2020 Extreme and Uncontrollable Circumstances Exception Application

If your practice experienced an extreme and uncontrollable circumstance outside of your control this year such as a natural disaster (e.g. hurricane) or public health emergency (e.g. COVID-19 pandemic), you can apply for the MIPS Extreme and Uncontrollable Circumstances Exception. 

The MIPS Extreme and Uncontrollable Circumstances Exception allows you to request one or more performance categories (i.e. Quality Measures or Improvement Activities) to be reweighted to 0%. 

We recommend submitting an application if your practice:

  • Experienced COVID-19 business interruption for a period of time
  • Experienced a significant decline in patient volumes
  • Furloughed staff for a period of time
  • Transitioned to virtual visits, making some quality measures ineligible
Each TIN can submit an application here. The deadline to complete an application has been extended to March 31, 2021 at 8 PM EST. Until written approval is received, continue reporting quality measures and performing improvement activities.

Submit an Exception Application

  1. Register for a HARP account. You can follow detailed instructions for creating your account here.
  2. Sign in to qpp.cms.gov
  3. Select Exceptions Applications on the left-hand navigation.
  4. Click Add New Exception.
  5. Select Extreme and Uncontrollable Circumstances Exception.
  6. Complete the application for individual, group, or virtual group.

Click here to watch a video tutorial from CMS.

Automatic Exception Circumstances

If your practice is located in a FEMA-designated disaster area affected by an extreme and uncontrollable event, there is no need to submit an Exception Application. All four MIPS performance categories will be automatically reweighted to 0% and you will receive a neutral payment adjustment. 

Exception Approval

Mandated therapists who do not report or report poor performance data are at risk of a financial penalty, so we strongly encourage submitting an Exception Application to avoid the penalty. Please use the QPP Participation Lookup Status Tool to see if you are mandated.

If you are not a mandated therapist, you do not need to submit an Exception Application. If you choose to submit, select the “Voluntary Reporting” option in order to obtain performance feedback without a financial risk.

After you have received written approval, you have the following options:

  • Keep MIPS enabled to access your scores and understand your performance data. This is recommended if this was your first year participating in MIPS. 
  • Discontinue MIPS altogether

Please note: If you are approved for the Exception AND you submit data for quality measures and improvement activities, CMS will void the exception. 

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