The Centers for Medicare and Medicaid Services (CMS) recently announced it has created an automatic extreme and uncontrollable circumstances exception for clinicians participating in the Merit-based Incentive Payment System (MIPS) who have been affected by California wildfires.

The "Extreme and Uncontrollable Circumstances" policy grants MIPS-eligible clinicians exceptions without having to submit an exception request. This automatic extreme and uncontrollable circumstances policy only applies to you if you’re an individual MIPS-eligible clinician in an affected area (determined by zip code and based on information in the Provider Enrollment, Chain and Ownership System [PECOS]). The automatic extreme and uncontrollable circumstances policy does not apply to groups or virtual groups, or MIPS-eligible clinicians in alternative payment models (APM), such as the Medicare Shared Savings Program.

Under this policy, MIPS eligible clinicians who are located in a designated region that has been affected by an extreme and uncontrollable event during the 2018 MIPS performance period will not be required to submit an application to reweight the performance categories under MIPS. Physicians affected by the California wildfires will automatically receive a neutral MIPS payment adjustment, unless they submit data for two or more MIPS performance categories by the 2018 submission deadline. Under the automatic extreme and uncontrollable circumstances policy, the Cost performance category will always be weighted at 0 percent, even if you submit data for the other performance categories.

While not covered by the automatic extreme and uncontrollable circumstances policy, MIPS eligible clinicians who is subject to the APM scoring standard and identified as affected by an extreme and uncontrollable circumstance may apply for an exception in the Promoting Interoperability performance category. Groups and virtual groups can complete an extreme and uncontrollable circumstance application if the fires have impacted their ability to collect data, at a group level, for a specific MIPS performance category.

In the final 2019 Medicare Physician Fee Schedule, CMS extended this automatic policy to future years of MIPS.

For more details, see the CMS fact sheet.