Advocacy Update

March 4, 2022: Advocacy Update spotlight on MIPS hardship exemption


Due to AMA advocacy, CMS has re-opened the 2021 Merit-based Incentive Payment System (MIPS) extreme and uncontrollable (E&C) hardship exemption process. Physicians have until March 31 to submit a 2021 exemption to avoid a 2023 negative payment adjustment.  

At the start of 2022, the AMA heard from multiple practices that were concerned they would receive a negative 2023 MIPS payment adjustment because they missed the 2021 MIPS E&C hardship application deadline and/or their end of year MIPS scores were impacted by the dramatic surge in COVID cases due to Omicron. The original E&C hardship application deadline coincided with the increase in COVID cases and as a result increased demands on practices. The re-opening of the 2021 application period will give physicians, including alternative payment model (APM) participants, much-needed relief and better ensure they avoid a 2023 MIPS negative payment adjustment. Physicians have until March 31, 2022, to submit an E&C application due to COVID.  

As a reminder, physicians who do not submit any MIPS data for the 2021 MIPS program will automatically avoid a 2023 penalty. If a physician, practice or physician/practice part of an APM is unsure of their status and believe you have been affected by the E&C circumstances (such as the public health emergency triggered by the COVID-19 pandemic), you can apply for this exception by March 31.

For more information, please see the Quality Payment Program COVID-19 Response webpage of the Quality Payment Program (QPP) website. You can contact the Quality Payment Program at (866) 288-8292, Monday through Friday, 8 a.m.–8 p.m. Eastern or by e-mail at: [email protected]. To receive assistance more quickly, please consider calling during non-peak hours—before 10 a.m. and after 2 p.m. Eastern. Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.