CMS to Apply MIPS Extreme and Uncontrollable Circumstances Policy In Response to COVID-19, Reopens Application

Members & Publications

April 3, 2020

CMS is offering multiple flexibilities to provide relief to clinicians responding to the 2019 Novel Coronavirus (COVID-19) pandemic. In addition to extending the 2019 Merit-Based Incentive Payment System (MIPS) data submission deadline to April 30, 2020 at 8 PM ET, the MIPS automatic extreme and uncontrollable circumstances policy will apply to MIPS eligible clinicians who do not submit their MIPS data by the April 30 deadline.

If you are a MIPS eligible clinician and do not submit any MIPS data by April 30, 2020, you won’t need to take any additional action to qualify for the automatic extreme and uncontrollable circumstances policy. You will be automatically identified and will receive a neutral payment adjustment for the 2021 MIPS payment year. Please note, CMS has updated the QPP Participation Status Tool so eligible clinicians can see if the policy has been automatically applied.

Additional 2019 Relief Measure

We are also reopening the MIPS extreme and uncontrollable circumstances application for individuals, groups, and virtual groups.

Who should submit an application?

  • Individual clinicians who started, but are unable to complete, their data submission;
  • Groups that started, but are unable to complete, their data submission; and
  • Virtual groups that are unable to start or complete their data submission.

An application submitted between April 3 and April 30, 2020, citing COVID-19, will override any previous data submission.

For more information, please see the Quality Payment Program COVID-19 Response Fact Sheet.

You can contact the Quality Payment program at 1-866-288-8292, Monday through Friday, 8:00 AM-8:00 PM ET or by e-mail at:

  • Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant


Legislation Introduced to Alleviate Impact of Conversion Factor Cut for 2021

Nov 09, 2020

Last month, two bills were introduced in the House proposing solutions to the estimated 10.6% Physician Fee Schedule conversion factor cut expected to go into effect January 1, 2021.  The bills offer some relief to the cut, but do not reflect a comprehensive or long-term solution.  AAPM&R has therefore chosen to remain neutral regarding these bills. 

Your Academy continues to advocate for a permanent solution to the conversion factor cut while maintaining the important payment increases to office and outpatient evaluation and management services.