New 2023 MIPS Automatic Hardships Announced!

The Centers for Medicare and Medicaid Services (CMS) recently announced that they have identified certain counties in Mississippi, Guam, Hawaii, Florida, and Georgia as qualifying for an automatic 2023 MIPS extreme and uncontrollable circumstances (EUC) hardship. This announcement comes in recognition of the impact of tornadoes in Mississippi, Typhoon Mawar in Guam, wildfires in Hawaii , Hurricane Idalia in Florida and Georgia.

In addition to all of Guam, the remaining affected counties in these territories are reflected in the maps from the FEMA Disaster Declaration below and have been included in CMS’ list of the areas qualifying for a 2023 MIPS automatic EUC:

Specific Counties within the Impacted Territories

Florida	Georgia	Guam	Hawaii	Mississippi
Alachua Baker Bay Bradford Brevard Calhoun Charlotte Citrus Clay Collier Columbia DeSoto Dixie Duval Flagler Franklin Gadsden Gilchrist Gulf Hamilton Hardee Hernando Hillsborough Jefferson Lafayette Lake Lee Leon Levy Liberty Madison Manatee Marion Nassau Orange Osceola Pasco Pinellas Polk Putnam Sarasota Seminole St. Johns Sumter Suwannee Taylor Union Volusia Wakulla	Appling Atkinson Bacon Berrien Brantley Brooks Bulloch Burke Camden Candler Charlton Clinch Coffee Colquitt Cook Echols Emanuel Glynn Jeff Davis Jenkins Lanier Lowndes Montgomery Pierce Screven Tattnall Thomas Tift Toombs Treutlen Ware Wayne	Guam County	Maui County Hawaii County	Carroll Humphreys Monroe Montgomery Panola Sharkey Washington

 

Important Notes for Those in the Identified Areas

• Clinicians might be automatically scored on certain categories in the following circumstances:
  • Clinicians in APMs automatically receive Improvement Activities credit and so are automatically scored on at least 1 MIPS category.
  • Submitting Quality Data Codes on Medicare Part B Claims: clinicians/groups submitting quality data codes on claims, even if only submitted prior to the announcement of the automatic EUC, will be scored at the individual level on Quality (1 MIPS category).
    • If you are part of an APM Entity: You will receive a MIPS Final Score and payment adjustment associated with the higher of your individual or APM Entity scores.
    • Group reporting is optional. If you have not reported and do not report any 2023 MIPS data at the group level, your clinicians will only be evaluated at the individual level (and have the automatic EUC applied).
      • You can still report on the individual level, if you would like.
    • All individual MIPS eligible clinicians who receive an automatic EUC exception will have Cost reweighted, regardless of whether they choose to report other performance categories.The Automatic EUC applies only to individual MIPS eligible clinicians. It does not apply to groups, virtual groups, or APMs.
• Do not submit data in the categories for which you received a hardship exception or CMS will score those categories.
  • If you submit data on 2+ MIPS categories, CMS will score you on the reported categories and assign you a 2023 MIPS final score and 2025 payment adjustment.
  • Reminder: Clinicians in APMs are automatically scored on Improvement Activities and clinicians who have submitted quality data codes on Medicare Part B claims at any point in 2023 will receive a Quality category score. If a clinician is both in an APM and has submitted any 2023 quality data codes on Medicare Part B claims, they will automatically have 2 MIPS categories scored.
• If you submit data on 1 or fewer MIPS categories, CMS will assign you a 2023 MIPS score equal to the threshold to avoid a penalty.
• If you get a hardship for all categories, CMS will assign you a score equal to the threshold to avoid a penalty.

Next Steps

• Share this information with your colleagues.
• Subscribe to our blog to get alerts on this and other important issues. You can subscribe using the field in our website footer below.
• If you are an Anatomy IT client
  • Contact your Client Success Manager if you have any questions or if you plan on using this automatic hardship. Your Client Success Manager will help you evaluate your eligibility and retain the necessary documentation on your behalf.
• If you are not an Anatomy IT client
  • Contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.

If you have any questions on this, let us know!

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Written By: Pramoda Bapatla, MPH

About the Author: Pramoda Bapatla, MPH is a Health Policy Analyst at Anatomy IT.