This content is excerpted from EyeNet’s MIPS 2021; also see the Academy’s MIPS hub page.
In some circumstances, CMS can reweight the performance categories. If CMS determines that you shouldn’t be scored on a performance category, it can reduce that category’s weight in your MIPS final score to zero and increase the weight of the other performance categories as shown in Table 1: How the Performance Categories Are Weighted. Here are some common scenarios:
- Promoting interoperability reweighted to zero. If you qualify for a promoting interoperability exception—because, for example, you are in a small practice and successfully apply for the “overwhelming barriers” exception—CMS can reduce the weight of that performance category to zero and increase quality’s weight from 40% to 65%. A quality score of 60% would now contribute 39 points (60% of 65 points) to your MIPS final score.
- Cost reweighted to zero. If you don’t perform cataract surgery, then it is unlikely that you will meet the case minimum for any of this year’s cost measures. If that’s the case, then CMS will not factor cost into your MIPS final score. Instead, it will reduce cost’s weight from 20% to zero and increase quality’s weight from 40% to 55% and promoting interoperability’s weight from 25% to 30%. A quality score of 60% would now contribute 33 points (60% of 55 points) to your MIPS final score, and a promoting interoperability score of 80% would contribute 24 points (80% of 30 points).
- What if both cost and promoting interoperability are reweighted to zero? Your quality score would now have a weight of 85%, meaning that a quality score of 60% would contribute 61 points (60% of 85 points) to your MIPS final score.
Emergencies. CMS can reweight performance categories if it determines that “extreme and uncontrollable circumstances” apply.
Table 1: How the Performance Categories Are Weighted
“Extreme and Uncontrollable” Circumstances
What if circumstances beyond your control limit your ability to participate in MIPS? You can apply to have your performance categories reweighted if you have difficulty reporting one or more performance categories due to “extreme and uncontrollable circumstances.” CMS hasn't yet set a date for when it will start reviewing applications, but last year it started in the summer. The application period will close on Dec. 31, 2021.
What is considered extreme and uncontrollable? It must be a rare event that is entirely outside of the control of yourself and of the facility where you work. The circumstances must prevent you—either altogether or for an extended period of time—from collecting information that you need to submit for a performance category. For example, a fire that destroys the only facility where a clinician works could be considered extreme and uncontrollable, but the inability to renew a lease for that facility wouldn’t. CMS will take into account the type of event, date of event, length of time over which the event took place, and other details that impact your ability to report each performance category.
During a widespread catastrophe, CMS may waive the application requirement for individuals. For example, if the Federal Emergency Management Agency declares a major disaster or public health emergency, CMS may decide to implement an automatic extreme and uncontrollable circumstances policy, which would mean that affected clinicians could have their performance categories reweighted without having to go through the application process. However, this automated reweighting would only be applied to individuals; if you are reporting as part of a group, your group would have to apply for the reweighting.
Note: In some years, CMS has not been able to publish a list of affected areas eligible for an automatic exemption before the end of the calendar year. If you are in a disaster zone, and your area hasn’t yet been flagged as eligible for an automatic exemption, consider applying for an “extreme and uncontrollable circumstances” reweighting before you miss the Dec. 31 application deadline.
What about COVID-19? For the 2020 performance year, CMS—in a late about face—waived the application requirement for COVID-related hardships. Don’t assume that it will also waive the application requirement for performance year 2021. If you want to reweight one or more performance categories to zero because of the pandemic, you should sumbit an "extreme and uncontrollable" circumstances hardship application.
How performance categories are reweighted. If CMS approves your application to reweight one or more performance categories to zero, the weight(s) would be reallocated as shown in “Table 1: How the Performance Categories Are Weighted,” above.
IMPORTANT: Don’t submit data to CMS on performance categories that are accepted for reweighting. CMS will not reweight a performance category if you report data for it after the triggering extreme and uncontrollable event.
CMS UPDATE: Automatic extreme and uncontrollable circumstances policy. On Nov. 10, 2021, CMS announced that it was expanding its response to the COVID-19 public health emergency. It said that it would apply an automatic extreme and uncontrollable circumstances policy to “all individually eligible MIPS eligible clinicians for the 2021 performance year. This doesn’t apply to groups, virtual groups, or APM entities. If you are eligible to participate in MIPS as an individual, CMS has said that you “will have all four MIPS performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless you 1) submit data in two or more performance categories, or 2) have a higher final score from group or APM Entity participation.” For more information, visit https://qpp.cms.gov/resources/covid19.
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