In response to the COVID-19 pandemic, the Centers for Medicare and Medicaid Services (CMS) will offer flexibilities to clinicians who chose (or were mandated) to participate in MIPS during the 2020 performance year. 

The Merit-Based Incentive Payment System (MIPS) is a Medicare payment program that rewards clinicians with financial incentives for improving the quality of care in their clinics—as per the standards of the program. Last year, 2019, was the first year that PTs, OTs, and SLPs could participate. While MIPS participation was optional for a large majority of rehab therapists, many chose to opt into the program in an effort to improve Medicare reimbursements for their clinics.

However, with the rapid spread of COVID-19 and its impact on the healthcare industry, CMS recognized that many MIPS participants may struggle to successfully report in 2020. So, on June 24, 2020, CMS announced that it would give 2020 MIPS participants some reporting flexibility.

Extreme and Uncontrollable Circumstances Application

CMS has opened up access to its Extreme and Uncontrollable Circumstances Application for MIPS participants. Through this application, participants (including individuals, groups, and virtual groups), can “request reweighting of one or more MIPS performance categories to 0%” due to hardship from extreme and uncontrollable circumstances—a pandemic, for example. 

Essentially, what this means is that, upon application approval, reweighted categories will not contribute to a final MIPS score. So, because PTs, OTs, and SLPs are currently only eligible to participate in two of the four MIPS categories (quality and improvement activities), they could ask to reweight one or both of these categories. 

CMS will review applications “on a case-by-case basis,” and the deadline to apply is December 31, 2020. Also, keep in mind that if you end up submitting performance data to CMS, it will void approved applications on a category-by-category basis.  

How to Submit an Application

MIPS participants can submit an Extreme and Uncontrollable Circumstances Application through the QPP website (linked below) by following these instructions from CMS

  1. Register for a HARP account (i.e., an account through the QPP) if you don’t have one. 
  2. Sign in to the QPP website.
  3. Select “Exceptions Applications” in the navigation bar on the left side of the page.
  4. Select “Add New Exception.”
  5. Select “Extreme and Uncontrollable Circumstances Exception.”
  6. Complete and submit the application. 

Please keep in mind that if you report MIPS as a group, then you must submit one application for the entire group.  

New COVID-19 Improvement Activity

For clinicians and groups that would like to continue participating in MIPS, CMS has added one new high-weighted improvement activity to the pool “to provide an opportunity for clinicians to receive credit in MIPS for the important work they are doing across the country.”

MIPS participants can receive credit for this activity in one of two ways: 

  • “A clinician may participate in a COVID clinical trial and have those data entered into a data platform for that study; or
  • A clinician participating in the care of COVID-19 patients may submit clinical COVID-19 patient data to a clinical data registry for purposes of future study.”

Please note that while rehab therapists can theoretically report this activity, many will not meet the activity’s logistics criteria. Therapists who work in physician practices are the most likely candidates to be eligible to report this activity.


MIPS participation always comes with a degree of risk—and, all things considered, this might be a good time to assess how much risk your clinic can assume. Have questions about MIPS or the flexibility that CMS is offering? Feel free to leave a question below!