On November 2, 2017, the Centers for Medicare & Medicaid Services (CMS) issued an interim final rule with comment period to address the California wildfires and Hurricanes Harvey, Irma and Maria. These disasters occurred during the 2017 performance period, and Quality Payment Program (QPP) participants in affected areas may qualify for an exemption under the Extreme and Uncontrollable Circumstances (EUC) policy recognized in the Medicare Access and CHIP Reauthorization Act final rule.
The CMS has granted exceptions to QPP reporting requirements for the 2017 performance period to Merit-Based Incentive Payment System (MIPS)-eligible clinicians without them having to submit an extraordinary circumstances exception request if the clinicians are within the Federal Emergency Management Agency (FEMA)-designated areas. The CMS will identify individual participant locations using the Provider Enrollment, Chain and Ownership System. Individual MIPS participants identified in the affected hurricane areas or California counties designated as major disaster counties will receive a neutral payment for the 2017 performance period and won’t be required to submit data for MIPS.
No Exceptions for MIPS APMs
The EUC policy only will apply to MIPS track-eligible clinicians. Eligible clinicians in MIPS Alternative Payment Models (MIPS APM) won’t qualify for the automatic neutral payment through this policy. MIPS APM participants aren’t included because CMS has assigned all APM Entities a score of 100 percent for the improvement activities (IA) performance category for the 2017 performance period. That score will earn the APM Entities at least a neutral payment adjustment. MIPS APM Entities aren’t required to report data to CMS for the IA category; therefore, they won’t be required to submit data to the CMS to receive a neutral payment adjustment.
The CMS has outlined how the 2017 performance year scoring is affected under the EUC policy:
- For MIPS-eligible clinicians identified as eligible for the automatic neutral payment, the CMS will assign a weight of zero percent to the MIPS final score. If the clinician or group doesn’t submit any data to CMS, it’ll receive a score equal to the performance threshold and a neutral payment adjustment.
- If a clinician qualifies for the reweighting under this policy but submits data to the CMS, the CMS will score the individual clinician or group on the data submitted and the MIPS payment adjustment will be based on that final score.
- If groups in the identified areas don’t submit data for MIPS, the CMS will treat all MIPS-eligible clinicians within the group as individuals. That means each MIPS-eligible clinician within the group will receive a neutral payment adjustment.
- In the event a group submits data to the CMS for MIPS, the EUC policy won’t apply and the CMS will score the group on the data submitted. The group’s payment adjustment will be based on the final score of the data submitted to the CMS.
Visit the FEMA website for more information regarding FEMA-designated areas. Additional information about the EUC policy can be found in the CMS Quality Payment Program resource library.