EUC (Extreme and Uncontrollable Circumstances) Hardship Exception for 2023

Patti Simms
Author / Quantician
2 min read
August 9, 2023

MIPS eligible clinicians, groups, and virtual groups are all eligible to submit an application to reweight any or all of the MIPS performance categories if they are/have been affected by rare events entirely outside of their control and the control of the facility where they practice that would: Cause them to be unable to collect information necessary to submit data for a MIPS performance category; Cause them to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (3 months or more); Impact their normal processes and affecting their performance on cost
measures and other administrative claims measures.

Clinicians that have registered to report a MIPS Value Pathway (MVP) as a subgroup will be covered by any reweighting approvals for their affiliated group. Alternative Payment Model (APM) Entities are only allowed to request reweighting for all performance categories. For 2023, COVID-19 will still be used as an acceptable reason to submit an application for reweighting. Regardless if a clinician or practice qualifies for automatic reweighting or has an approved exception application, they can still report data. If data is submitted for 2 or more MIPS performance categories, they will receive a final score based on the performance in these categories

APM Entities participating in MIPS APMs are also eligible to apply for a MIPS EUC Exception. There are a few differences for APM’s listed below:

APM Entities can only request reweighting for all performance  
 categories.
At least 75% of the eligible clinicians in the APM Entity must qualify for   
 reweighting in the PI performance category.
If an APM qualifies for an EUC exception and submits data the data 
 submission will not override performance category reweighting.

To determine if a clinician or practice has already been assigned a Special Status at the clinician or practice level, SIGN IN to the Quality Payment Program website with your HARP credentials and check the QPP Participation Status Tool on the Eligibility & Reporting page. Please note that practice level special statuses apply to both group and subgroup reporting. If an automatic exception is indicated, please verify which exception (PI or EUC) it is, prior to taking or not taking any action. If the exception is correct, no application is necessary. If no exception is listed, click ‘Exceptions Application’ and select ‘Extreme and Uncontrollable Circumstances.’ The application deadline for 2023 is 8 p.m. ET on January 2, 2024.

The results of your application will be sent via email. If approved, your eligibility profile will reflect the exception. If your application is not approved until the end of the year, it may not appear in the QPP Participation Status Tool until the MIPS submission window opens in 2024.

Patti Simms
Author / Quantician

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