New 2024 and 2025 MIPS Automatic Hardships Announced for Los Angeles
The Centers for Medicare and Medicaid Services (CMS) recently announced that they have identified Los Angeles County in California as qualifying for an automatic 2025 MIPS extreme and uncontrollable circumstances (EUC) hardship and an automatic 2024 MIPS EUC hardship. Meaning that MIPS eligible individual clinicians will be eligible for an automatic hardship for both 2024 and 2025 performance years as long as they do not submit and have not submitted any MIPS data.
This announcement comes in recognition of the devastating impact of the Los Angeles wildfires.
Is my location eligible for an automatic hardship?
Only Los Angeles County (FEMA-declared major disaster area) is eligible for the automatic hardship. Please note, the automatic EUC only applies to individual MIPS eligible clinicians (it does not apply to group, subgroup, virtual group, or APM Entity participation).
Important Notes for Those in the Identified Areas
- As this automatic EUC hardship applies to both 2024 and 2025, we will refer to “the relevant performance year” in the bullets below to indicate that it should be evaluated for 2024 and 2025 independently.
- For example, if you report 2+ categories for 2024, that will not impact your 2025 performance year and vice versa.
- 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).
- The Automatic EUC applies only to individual MIPS eligible clinicians. It does not apply to groups, virtual groups, or APMs.
- 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 performance year 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.
- If you group report and you do not exceed the low-volume threshold at the individual level, you will only receive the group score.
- 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.
- 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 MIPS final score and payment adjustment for the relevant performance and payment year.
- 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 for the relevant performance year (either 2024 or 2025) will receive a Quality category score. If a clinician is both in an APM and has submitted any quality data codes on Medicare Part B claims in the relevant performance year, they will automatically have 2 MIPS categories scored.
- If you submit data on 1 or fewer MIPS categories, CMS will assign you a 2025 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.
- If you submit data on 2+ MIPS categories, CMS will score you on the reported categories and assign you a MIPS final score and payment adjustment for the relevant performance and payment year.
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 MIPS Expert if you have any questions or if you plan on using this automatic hardship. Your MIPS Expert 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!
Written By: Jessica Peterson, MD, MPH
About the Author: Jessica Peterson, MD, MPH is the Senior Director of Value-Based Care Policy at Anatomy IT.
