The Federal Government has published information on Extreme and Uncontrollable Circumstances Exemptions as a result of Hurricanes Milton, Helene, and Francine. At the bottom of their document is a note
NOTE: The MIPS automatic EUC policy doesn’t apply to MIPS eligible clinicians participating in MIPS as a group, subgroup, virtual group, or Alternative Payment Model (APM) Entity. However, groups, virtual groups, and APM Entities can request reweighting through the EUC Exception application. Subgroups will inherit any reweighting approved for their affiliated group; they can’t request reweighting independent of their affiliated group’s status.
For a listing of all Disasters declared by FEMA in 2024 use this link:
Disasters and Other Declarations | FEMA.gov
If you are in one of the disaster areas call the QPP help desk to see if you have a MIPS exemption as an INDIVIDUAL. Please remember these automatic exemptions do not apply to groups. All groups must submit applications for exemptions
If you are part of a group, subgroup, or virtual group you CAN NOT expect an automatic exemption even if you are in one of the areas designated in their notification.
There are also other reasons you may not be required to submit MIPS data. There is ONLY ONE source of truth for this information and that is the QPP website at https://qpp.cms.gov. When you visit that page there is a box that says Check your participation status. You need to enter your INDIVIDUAL NPI in that box. Please do not enter your group NPI it simply will not work.
When you enter your individual NPI it will give you information on your requirements. You may see multiple entries if you are associated with multiple practices
Each time you will see your name at Practice Name
Below that you will see your address and your eligibility information. One of my entries looks like this:
The Individual has a black circle next to it and the group has a black circle next to it. That means that as part of Long Island Podiatry PC I do not have to report as an individual or a group. Looking below that it shows that I am Opt-In eligible as an individual and a group which means I can report and participate in MIPS if I want to but I am not required to do so.
The Expand link to the right of my information provides more information on my participation status. When I click on that in this case I see:
Another search on another provider has the following results:
Here you see the GROUP is green. This provider must report as part of their group, they are not required to report as an individual. If the group does not report, the group is potentially subject to a 9% MIPS penalty. Clicking on the Expand link produces the following information
A third search has the following results
In this case Individual and Group reporting is required.
Clicking on the expand button gives the following information:
Finally at the bottom of the page is a phone number you can call to help you understand MIPS and your reporting obligations
If you are required to report and you need assistance or if you have any questions about MIPS you can always reach out to Dr Brody via email at mbrody@tldsystems.com or he has an online calendar and you can request a web meeting where he will be happy to visit the QPP website with you and help you to understand what your responsibilities are related to MIPS. To schedule a web meeting click the following link: https://calendly.com/d/3b2-p64-pb9
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