2017/2018 MIPS Exclusions

Extreme and Uncontrollable Circumstances Over the past several months, numerous clinicians have been affected in many areas of the country due to Hurricanes Harvey, Irma, and Maria, which occurred during the 2017 MIPS performance period.

CMS addresses  extreme and uncontrollable circumstances for both the transition year and the 2018 MIPS performance period in this final rule with comment.

• For the transition year, if a MIPS eligible clinician's CEHRT is unavailable as a result of extreme and uncontrollable circumstances (e.g., a hurricane, natural disaster, or public health emergency), the clinician may submit a hardship exception application to be considered for reweighting of the Advancing Care Information performance category. This application is due by December 31, 2017.  

• Reweighting policy for the three other performance categories (Quality, Cost, and Improvement Activities) starting with the 2018 MIPS performance period. This hardship exception application deadline is December 31, 2018.

• Policies relating to reweighting the Quality, Cost, and Improvement Activities performance categories are not effective until next year, an interim final rule for automatic extreme and uncontrollable circumstances where clinicians can be exempt from these categories in the transition year without submitting a hardship exception application (note that cost has a 0% weight in the transition year). 

What does that mean for 2017? 

• Clinicians in affected areas that do not submit data will not have a negative adjustment.

• Clinicians that do submit data will be scored on their submitted data.  This allows them to be rewarded for their performance in MIPS.  Because MIPS is a composite, clinicians have to submit data on two or more performance categories to get a positive payment adjustment.  

• The policy applies to individuals (not group submissions), but all individuals in the affected area will be protect for the 2017 MIPS performance period. 

• MIPS eligible clinicians who are eligible for reweighting due to extreme and uncontrollable circumstances, but still chooses to report (as an individual or group), will be scored on that performance category based on their results.  

• This policy does not apply to APMs.