Thanks to medicine’s advocacy, the Centers for Medicare & Medicaid Services (CMS) has reopened a hardship exception for the 2023 Merit-Based Incentive Payment System (MIPS) performance period to account for February’s Change Healthcare cyberattack.
Physicians affected by that cyberattack now have until 7 pm CT on Oct. 11 to apply for the Extreme and Uncontrollable Circumstances (EUC) exception. Those who were unable to submit 2023 data prior to the Mar. 31, 2024, deadline – solely due to the Change Healthcare cyberattack – can no longer submit data but can request reweighting.
CMS will allow eligible MIPS clinicians and groups to request reweighting of up to four MIPS performance categories for performance year 2023, which affects 2025 payments. In a departure from the norm, applicants must request the EUC through the MIPS targeted review process rather than the EUC application form.
“If a MIPS-eligible clinician is scored on two or more performance categories, we will calculate a MIPS final score in accordance with our weighting policies,” CMS clarified in a notification to physicians. “If a MIPS-eligible clinician is scored on fewer than two performance categories, then they will receive a final score equal to the performance threshold.”
The American Medical Association, in an email notifying membership of its work to secure the reopening, specified that if a physician or group already submitted 2023 data for a category, CMS will continue scoring that category using those data.
“We encourage practices to consider submitting the application for the cost performance category, at a minimum, as there are no data submission requirements for the cost measures, which CMS scores using claims data,” AMA advised.
The Feb. 21 cyberattack initially disrupted many practices and has had lingering effects as evidenced by the EUC reopening.
“For some Texas physicians, money stopped entirely,” recalled Shannon Vogel, the Texas Medical Association’s associate vice president of health information technology, of its immediate effects. “It impacted a lot of payment systems downstream, even Medicare payments.”
Ms. Vogel noted that this reopening of the EUC is an unusual move by CMS, and “shows good advocacy” from AMA, enabling physicians to improve their MIPS final scores for 2023.
To apply for reweighting, visit the Quality Payment Program page on the CMS website, and download this PDF containing step-by-step instructions with screenshots to walk through the application process.
The MIPS EUC Exception Application form currently accessible on the QPP website is for 2024 only and can’t be used to request reweighting for 2023.
As Texas Medicine Today reported, CMS also previously added the Change Healthcare cyberattack, under the “ransom/malware” event type, to the 2024 MIPS EUC portal. Physicians affected by the cyberattack for 2024 MIPS reporting have until Dec. 31 to file a hardship application and avoid a 2026 MIPS negative payment adjustment.
Phil West
Associate Editor
(512) 370-1394
phil.west[at]texmed[dot]org
Phil West is a writer and editor whose publications include the Los Angeles Times, Seattle Times, Austin American-Statesman, and San Antonio Express-News. He earned a BA in journalism from the University of Washington and an MFA from the University of Texas at Austin’s James A. Michener Center for Writers. He lives in Austin with his wife, children, and a trio of free-spirited dogs.