The Centers for Medicare & Medicaid Services (CMS) recently released the 2020 Quality Payment Program (QPP) Exception Applications Fact Sheet. The fact sheet explains how to apply two types of exceptions: the Promoting Interoperability (PI) Hardship Exception and the Extreme and Uncontrollable Circumstances Exception. If individual clinicians, groups, and virtual groups meet certain criteria for a PI exception or experience extreme and uncontrollable circumstances—such as a natural disaster or public health emergency (including the COVID-19 pandemic)—they can submit an application to reweight their Merit-based Incentive Payment System (MIPS) Quality, Cost, Improvement Activities, and/or PI performance categories.

The fact sheet also explains situations where the automatic extreme and uncontrollable circumstance policy would be applied to individual clinicians located in a CMS-designated area affected by an extreme and uncontrollable event during 2020. However, CMS has not yet announced the COVID-19 pandemic as a triggering event for the automatic extreme and uncontrollable circumstances policy for the 2020 MIPS performance year. Therefore, if your 2020 MIPS data collection and reporting has been disrupted by the COVID-19 pandemic, you should submit application(s) for the extreme and uncontrollable circumstances policies.

To learn more, view the 2020 MIPS Exceptions Applications Fact Sheet here. Additional questions can be directed to QualityDC@facs.org.