Are You Eligible to File a MIPS Extreme and Uncontrollable Circumstance (EUC) Application?
As the 2023 MIPS year approaches its end, high performance stakes and reimbursement outcomes are key. However, there may be a critical reason that you need to or may be eligible to sit out for the year with a hardship or extreme and uncontrollable circumstances application. There are a few extenuating circumstances that qualify you for an exemption. Here is all you need to know about Hardship and EUC applications.
Category Hardship Application
A hardship application is filed with the Centers for Medicare and Medicaid Services (CMS) to request an exemption from MIPS reporting. CMS has identified several reasons that may warrant a hardship exemption. Hardship exceptions are available for the following specified reasons:
You have decertified EHR technology
You have insufficient Internet connectivity
You face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
You lack control over the availability of CEHRT
In order to qualify, documentation that verifies the hardship is required.
Extreme and Uncontrollable Circumstances Application
An Extreme and Uncontrollable Circumstances (EUC) application is filed with CMS to request an exemption from MIPS reporting for natural disasters or other emergency situations that are out of the control of the MIPS eligible clinician. This also requires applicants to provide documentation that verifies the EUC.
6 potential reasons for MIPS hardship under uncontrollable circumstances:
Natural Disasters: Disruptions from events like hurricanes, floods, or earthquakes.
Public Health Emergencies: Situations like the COVID-19 pandemic affecting practice operations.
Financial Distress: Challenges like bankruptcy preventing data collection/reporting.
Clinician/Staff Issues: Sudden personnel changes or severe illnesses.
EHR Challenges: Significant downtimes or technology issues impeding data collection.
Extreme Circumstances: Other major, uncontrollable events affecting performance.
Documenting for either of these applications is cruicial. It is imperative to write-up how and why you qualify to sit out for the performance year or category. What happened? Did it impact you for the whole year or disrupt operations for a significant period of time? Do you have supporting documentation to help substantiate the issue or circumstances? If so, all of it needs to be very well written and confirmed.
Deadline
The deadline to file a Hardship or EUC application for the 2023 MIPS performance year is January 2nd, 2024.
The Consequences
If you do not submit a Hardship or EUC application by the deadline or if your application is denied, you will be required to participate in MIPS for the 2023 performance year. This means that you will be subject to the MIPS payment adjustment for the 2025 payment.
How To File
If you believe you have reason to file either a Hardship or EUC application, Chirpy Bird is here to help! We can file a compliant MIPS EUC on your practices’ behalf. With everything else that is going on, you can take this off your list. We can provide peace of mind that it will get done - timely and correctly.
If you are a clinician or practice who needs help filing an EUC, Chirpy Bird can help for a low low price!*
To get expert help documenting and filing your application or to learn more about Hardship and Extreme and Uncontrollable Circumstance Applications, please visit us at www.chirpybirdinc.com or email us at hello@chirpybirdinc.com
*new clients only.
