The Centers for Medicare and Medicaid Services (CMS) has extended the 2022 application deadline for COVID-19-related MIPS hardships to March 3, 2023 at 8 pm ET. CMS has also announced that they will not be applying an automatic COVID-19 hardship for the 2022 performance year, so if you need a 2022 hardship due to COVID-19, be sure to apply.
The Extreme and Uncontrollable Circumstance (EUC) hardship application is available in your QPP account. Remember that applications received by March 3, 2023 won’t override any submitted data.
New for 2022 MIPS: Small practices (<15 clinicians) get automatic PI hardship as long as they do not submit any data for the 2022 PI category.
Factors CMS Considers in Hardship Applications
CMS reviews applications taking into account both the event circumstances (what happened) and the timing (how long the circumstances impacted you) to assess your ability to collect and/or submit data for each performance category selected in the application.
- For the Cost and Quality category exceptions, CMS generally expects the circumstance to have lasted for at least 3 months.
- For example, COVID-19 prevented you from collecting Quality data for 3 or more months.
- Because the Improvement Activities (IA) and PI categories have shorter performance periods (only 90 days), CMS expects the circumstances affecting performance or preventing performance in those categories to be more prolonged.
Steps to Apply
If you are a MarsdenAdvisors client, contact your Client Success Manager to complete this process for you, otherwise:
- Sign in to your QPP account.
- Select “Exception Applications” on the left-hand navigation.
- Select “Add New Exception”.
- Select “Extreme and Uncontrollable Circumstances Exception”.
- Complete the application at either the individual, group, virtual group, or APM Entity participation level.
- After you submit your application, you will receive a message and an email stating that your application has been successfully submitted and is pending review.
- Once your application has been reviewed and a decision has been made, CMS will post the decision to your QPP account. You can also monitor your application status from there.
- The deadline to submit COVID-related EUC hardship applications is March 3, 2023 at 8 pm ET.
- Retain documentation of the hardship for at least six years in case of an audit.
- Hardships from previous years do not carry forward. You must submit a new application each year in which you experience a hardship.
- If you are granted a hardship:
- 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 2022 MIPS final score and 2024 payment adjustment.
- If you submit data on 1 or fewer MIPS categories (such as small practice claims-based Quality reporters), CMS will assign you a 2022 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.
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- If you are a MarsdenAdvisors client
- Contact your Client Success Manager if you have any questions or if you plan on applying for a hardship. Your Client Success Manager will submit the application and retain the necessary documentation on your behalf.
- If you are not a MarsdenAdvisors client
- Contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.