CMS Reminder: CMS Proposes to Allow APM Entities to Submit Applications for the Extreme and Uncontrollable Circumstances Exception; Applications are Due December 31

“In the 2021 Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM), the Centers for Medicare & Medicaid Services (CMS) proposed to allow APM Entities to submit an application to reweight Merit-based Incentive Payment System (MIPS) performance categories as a result of extreme and uncontrollable circumstances. We intend to allow APM Entities to submit applications now, but CMS will not be able to make final determinations on applications until and unless the policy proposal is finalized.

If the policy is finalized and an APM Entity’s application is approved, that APM Entity would receive a final score equal to the performance threshold for the 2020 MIPS performance year, and the MIPS eligible clinicians in the APM Entity group would receive a neutral payment adjustment in 2022.

Who is Eligible to Submit an Application?

If the policy is finalized, then APM Entities affected by extreme and uncontrollable circumstances in the following models would be able to submit an application:

  • Medicare Shared Saving Program
  • Next Generation ACO Model
  • Vermont Medicare ACO Model
  • Comprehensive Primary Care Plus (CPC+)
  • Comprehensive ESRD Care (CEC)
  • Bundled Payments for Care Improvement (BPCI)
  • Oncology Care Model (OCM)
  • Maryland Primary Care Program
  • Independence at Home Demonstration

What are the Application Requirements?

Unlike those who choose to apply as individual clinicians, groups, or virtual groups, APM Entities must apply to reweight all MIPS performance categories to 0%. Additionally, 75% of the MIPS eligible clinicians in the APM Entity must qualify for reweighting in the MIPS Promoting Interoperability performance category. They may qualify automatically or through a MIPS Promoting Interoperability Hardship Exception Application.

CMS does not require APM Entities to submit documentation with their applications. However, APM Entities should retain documentation of the circumstances supporting their application for their own records in the event they are selected by CMS for data validation or an audit.

When are Applications Due?

Applications are due to CMS by Thursday, December 31, 2020 at 8:00 p.m. ET.

How do I Apply?

New for 2020: You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you register for a HARP account, sign in to, select ‘Exceptions Applications’ on the left-hand navigation, select ‘Add New Exception,’ and select ‘Extreme and Uncontrollable Circumstances Exception.’

How do I Know if I’m Approved?

If you submit an application and this policy is finalized to allow APM Entities to apply, then you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but it may not appear in the tool until the submission window is open in 2021.

Will Submitting Data Void the Exception?

Data submitted for an APM Entity will not override performance category reweighting from an approved application. This differs from the policy for individual, group, and virtual group applications.

Will an Approved Application Affect Model-Specific Reporting Requirements?

If the policy is finalized and an APM Entity’s application is approved, the approval would only affect MIPS reporting, and that APM Entity would still be required to meet its model-specific reporting requirements.

For More Information


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