The MIPS COVID-19 EUC Exception has Expired – Here’s what it Means for You!

Beginning in the 2020 Performance Year (PY20), the Centers for Medicare and Medicaid Services offered a COVID-19 Extreme and Uncontrollable Circumstance (EUC) Hardship Exception. This allowed clinicians and groups to reweigh one or more performance categories if their practice was unable to collect, report, or submit MIPS data due to COVID-19 related circumstances. However, for the 2024 Performance Year (PY24) CMS is no longer accepting EUC applications for COVID-19 related circumstances.

Since this EUC hardship exception has been available for four consecutive Performance Years, there may be clinicians or groups who will have to fully report MIPS for the first time. Here’s how you can best navigate MIPS post-COVID EUC:

Check Eligibility

If you plan to report MIPS data for the first time, the first step is to check your MIPS eligibility. Participating in MIPS is mandatory clinicians who:

  • Have more than 200 Medicare Part B patients.
  • Have more than $90,000 in associated medical billing per year.
  • Cover more than 200 professional services during the performance period.

You can see a list of clinician types required to report, as well as special exceptions for reporting in our 2022 blog about eligibility. You can also check your eligibility status through CMS’ QPP Participation Portal.

Performance Categories

Since the EUC exception allowed clinicians to reweigh some or all performance categories, many clinicians will have to report data for Quality, Improvement Activities, and Promoting Interoperability for the first time.

Quality Category

This category requires a clinician to report on at least six quality measures including one outcome-based measure or high priority measure. A full list of quality measures for PY24 can be found using CMS’ measures tool.

You can learn more about this category in our PY23 blog on collecting Quality data.

Improvement Activities

Within traditional MIPS, you are supposed to report on the following within this category:

  • Large Practices: 2 high-weighted or 4 medium-weighted Improvement Activities or 1 High weighted and 2 medium-weighted activities.
  • Small Practice: 1 High weighted activity or 2 medium-weighted activities.

There are a total of 106 Improvement Activities for PY24.

Promoting Interoperability

CMS wants to ensure that your practice is engaging in interoperability by promoting patient access to health information and by sharing, analyzing, and interpreting healthcare data. This category has a performance period of any 180 continuous days throughout the year and represents 25% of your final score.

MIPS Value Pathways (MVPs)

MVPs are a reporting option that offers clinicians a subset of measures and activities relevant to a specialty or specific medical condition. Clinicians can select, collect, and report on a reduced number of quality measures and improvement activities as compared to traditional MIPS. However, you are still required to report on the complete Promoting Interoperability (PI) measure set. CMS will collect and calculate data in the Cost Performance category and Population Health Measures.  There are 16 MVPs currently finalized for the 2024 Performance Year.

You can learn more about MVPs by reading our 2024 MVPs blog.

How HCIS can Help!

Whether you’re brand new to MIPS, or have been reporting for years, Healthcare Innovation Solutions (HCIS) wants to provide as much support as possible to help you through the stress and difficulties of the submission process. If you took advantage of the COVID-19 EUC in the past and would like to speak with a MIPS expert, you can schedule a FREE 15-minute consulting session here.

You can also view our Pricing & Services page to see exactly what we offer in terms of consultation and submission help.