This content is excerpted from EyeNet’s MIPS 2022: A Primer and Reference; 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 “How the Performance Categories Are Reweighted.” Here are some common scenarios:
- Promoting interoperability reweighted to zero. If a clinician qualifies for a promoting interoperability exception—because, for example, she is automatically eligible for the small practice exception—CMS can reduce the weight of that performance category from 25% to 0%. Because she is in a small practice, her quality score’s weight would increase from 30% to 40% and the weight of her improvement activities score would increase from 15% to 30%. A quality score of 60% would now contribute 24 points (60% of 40 points) to her MIPS final score, and an improvement activities score of 100% would contribute 30 points (100% of 30).
- Cost reweighted to zero. If a clinician doesn’t perform cataract surgery, then it is unlikely that she 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 her MIPS final score. Instead, it will reduce cost’s weight from 30% to zero and increase other performance categories accordingly (see “How the Performance Categories Are Reweighted,” below).
- Emergencies. CMS can reweight performance categories if it determines that “extreme and uncontrollable circumstances” apply.
Table: 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 Jan. 3, 2023. (Note: CMS had initially set a Dec. 31 deadline, but has changed that to Jan. 3 for performance year 2022.) (Update: On Dec. 29, CMS announced that it was extending the deadline to apply for an extreme and uncontrollable circumstances reweighting if you are citing the COVID-19 public health emergency as the triggering event. The new deadline is March 3 at 8:00 p.m. ET. The agency also noted that any applications that it receives between Jan. 3 and March 3 wouldn't override any data that had been submitted.)
Update: On May 3, CMS announced that it had opened the application process, and MIPS eligible clinicians and groups could submit applications for the "extreme and uncontrollable circumstances" exception for performance year 2022.
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 turn-of-year application deadline.
What about COVID-19? Late in 2021, CMS announced that it had waived the application requirement for COVID-related hardships. Don’t assume that it will also waive the application requirement for performance year 2022. If you want to reweight one or more performance categories to zero because of the pandemic, you should submit an "extreme and uncontrollable" circumstances hardship application. For CMS updates, visit https://qpp.cms.gov/resources/covid19.
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.
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