The MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application is open through the end of the year. Groups/clinicians who don’t usually report MIPS or have no MIPS-eligible clinicians may consider applying for the EUC to ensure no downside risk.
Groups/clinicians significantly impacted by the Change Healthcare outage should consider filing a MIPS EUC Exception application. You can submit an application for any of the MIPS Performance categories (quality, cost, improvement activities, and promoting interoperability) if you have experienced Extreme and Uncontrollable Circumstances. EUCs are defined as rare events entirely outside of your control and the control of the facility in which you practice that may:
- Cause you to be unable to collect the information necessary to submit for a MIPS performance category.
- Cause you to be unable to submit the information used to score a MIPS performance category for an extended period (for example, if you failed to collect data for the quality performance category for three months).
- Impact your every day processes and affect your performance on cost measures and other administrative claims measures.
Anyone wanting to apply for an EUC should:
- Sign in to the QPP website with your Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) account.
- If you are applying for a group EUC, ensure you log into the group (TIN) QPP account.
- Choose “Exceptions Application” from the left-hand navigation.
- Click “Add New QPP Exception” on the right side of the screen.
- Choose “MIPS Extreme and Uncontrollable Circumstances Exception Application”.
- Select the performance categories impacted (likely Quality, Cost, Promoting Interoperability, and Improvement Activities).
- Enter reason for EUC, e.g., “Impact of Change Healthcare on our operations and ability to run the business.”
- Enter the impacted timeframe or check the “Still Affected” box if the impact of the Change Healthcare outage is still affecting your group.
Note: We recommend keeping all supporting documentation around your EUC circumstances in case of audit, e.g., loss of revenue, staffing reductions, and other supporting documents.
Additional CMS resources:
- Quality Payment Program Access User Guide (ZIP, 3MB)– Refer to “Step 1: Register for a HARP Account.”
- QPP Exception Applications
- 2024 MIPS Promoting Interoperability Hardship Exception Application Guide (PDF, 1MB)
- 2024 MIPS Extreme and Uncontrollable Circumstances Exception Application Guide (PDF, 1MB)
The Ventra Quality team is here to support you with your Quality/MIPS Reporting needs. Please reach out to Lance Mueller, Director of Healthcare Quality, with any questions.
