EUC Exception for MIPS Reporting in Performance Year 2023

Things don’t always go how we plan them. An effective program includes flexibility to cope with unexpected conditions in a controlled way. That’s what the Merit-based Incentive Program of QPP is doing with the hurdle coming in reporting since 2019.

Just like assigning special statuses to MIPS participants, MIPS reporting also has another go-to option for them. This option lessens the reporting load of those participants dealing with unwanted circumstances. So, QPP MIPS provides two exemption applications for reporting in the performance year 2023. These two options are:

1. MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application
2. MIPS Promoting Interoperability Performance Category Hardship Exception application

Here in this article, we will be especially discussing details about the MIPS EUC Exception. Continue reading if you have any queries regarding the EUC Exception application like:

• What is the EUC Exception?
• Who is eligible for a EUC Exception application?
• What is the procedure for this Exception application?

 EUC Exception Application in MIPS Program

EUC Exception in MIPS reporting is an acronym for ‘Extreme and Uncontrollable Circumstances’. As it is clear from its full name the application facilitates the participants during unexpected scenarios. In other words, if a participant is unable to submit the required measures during the performance year for some solid reason, they can apply for this exception. The EUC Exception application permits them to reweigh either any or all MIPS categories if they find them eligible.

The question that might come at this point is, what kind of extremely uncontrollable situations these could be? The MIPS 2023 has clearly defined all such circumstances and specifications for an application to be considered.

Anyhow, just for a rough idea, let me quote here a PHE. The World has recently gone through one such devastating situation. Yes, it is none other than the pandemic Covid-19. CMS has included new CPT codes for Covid-19 as well. Similarly, it provides reporting relaxations to clinicians in all QPP Pathways.

Circumstances; When to Request for Exemption Application?

This exemption application is specifically precise on ‘Extreme and Uncontrollable Circumstances’. It refers to any unaccustomed scenario that Is unmanageable for you and your facility and hinders the MIPS reporting.

For instance, any Public Health Emergency (PHE) in which:

• You may be unable to collect the necessary information for QPP MIPS.
• And if managed to collect information somehow could not submit data to CMS within the given period.
• You may encounter a situation that obstructs your facility’s internal processes. You may encounter a situation that obstructs your facility’s internal processes. This disaster may affect your performance on cost measures and administrative claims measures.

For all such problematic conditions, MIPS reporting 2023 has chosen the same solution as it does in MIPS 2022. It permits all MIPS-eligible clinicians, groups, and virtual groups to request any or all MIPS performance categories reweighting. It is solely the CMS’s decision whether to approve your application or not. The application approval depends on the fulfillment of certain preset criteria.

Clinicians who register to report a MIPS Value Pathway (MVP) as a subgroup may also apply at the subgroup level. However, the Exception application for their affiliate group will take precedence. QPP MIPS also welcomes applications for Alternative Payment Model (APM) Entities. However, they must include a reweighting proposal for all performance categories.

EUC Exception Application Process for MIPS Reporting

CMS has already scheduled its MIPS 2023 agenda and provided the details about related events on QPP Portal. So, participants can submit requests for MIPS EUC Exception in spring 2023. The exact date for the opening of the Exception application option is not determined yet. However, CMS has predetermined the closure of the exemption application that is on January 2, 2024 (at sharp 8 p.m.).

One can easily submit their MIPS EUC Exception application if one sticks to the following steps:

1. First, participants must have a Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) account. Only then, they are ready for submission of applications.
   1. If you do not have an account, then make one before it’s too late.
   2. If you have an account, get started by signing in to QPP with your HARP credentials.
2. Have a glimpse of left-hand navigation on the opened tab and select ‘Exceptions Application’.
3. Afterward, pick the ‘Extreme and Uncontrollable Circumstances’ option.
4. Now, all you have to do is wait for your application approval. You will receive an email notification about your application approval or denial.

Or

You can also check your eligibility profile at QPP Participation Status Tool on a rolling basis.

Note: If your MIPS EUC Exception application is approved at the end of PY 2023, QPP Participation Status Tool may not update your status. It will automatically update your eligibility profile when the submission window will reopen in 2024. 

Conclusion

MIPS EUC Exception application for MIPS 2023 is a convenient method for dealing with any unwanted problems in your MIPS reporting journey. QPP MIPS has facilitated all such participants to get approval from CMS for reweighting any or all MIPS reporting categories. This is an approach to save the participants from penalties by being affected by any ‘Extreme and Uncontrollable Circumstances’.