2020 Extreme and Uncontrollable Circumstances Exception and Promoting Interoperability Hardship Exception Applications are Due December 31

Extreme and Uncontrollable Circumstances Application & COVID-19

The COVID-19 pandemic has impacted all clinicians across the United States and territories. However, CMS recognizes that not all practices have been impacted by COVID-19 to the same extent. For the 2020 performance year, CMS will be using our Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency.

If you have any concerns about the effect of the COVID-19 pandemic on your performance data, including cost measures, for the 2020 performance period, submit an application now and be sure to cite COVID-19 as the reason for your application.

If you have an approved application, you can still receive scores for the quality, improvement activities and Promoting Interoperability performance categories if you submit data. If the cost performance category is included in your approved application, you will not be scored on cost measures even if other data are submitted.

Learn more in the 2020 Exceptions Applications Fact Sheet.

Note: CMS has proposed to allow APM Entities to submit an application to reweight MIPS performance categories as a result of extreme and uncontrollable circumstances, such as the public health emergency resulting from the COVID-19 pandemic. Learn more in the 2021 Quality Payment Program Proposed Rule Overview Fact Sheet.

MIPS Promoting Interoperability Hardship Exceptions

MIPS eligible clinicians, groups, and virtual groups may qualify for a re-weighting of the Promoting Interoperability performance category to 0% if they:

  • Are a small practice;
  • Have decertified EHR technology;
  • Have insufficient Internet connectivity;
  • Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues; or
  • Lack control over the availability of CEHRT.

Note: If you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply.

How do I Apply?

New for 2020: You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself, or another MIPS eligible clinician, group ,virtual group or APM Entity.  For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you register for a HARP account, sign in to qpp.cms.gov, select ‘Exceptions Applications’ on the left-hand navigation, select ‘Add New Exception,’ and select ‘Extreme and Uncontrollable Circumstances Exception’ or ‘Promoting Interoperability Hardship Exception.’

How do I Know if I’m Approved?

If you submit an application for either of the exceptions, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but may not appear in the tool until the submission window is open in 2021.

For More Information


Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.

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



CMS Takes Steps to Ensure Medicare Beneficiaries Have Wide Access to COVID-19 Antibody Treatment

CMS announced that starting November 10, Medicare beneficiaries can receive coverage of monoclonal antibodies to treat COVID-19 with no cost-sharing during the Public Health Emergency (PHE). CMS’ coverage of monoclonal antibody infusions applies to bamlanivimab, which received an Emergency Use Authorization (EUA) from the FDA on November 9.

“Today, CMS is announcing a historic, first-of-its kind policy that drastically expands access to COVID-19 monoclonal antibodies to beneficiaries without cost sharing,” said CMS Administrator Seema Verma. “Our timely approach means beneficiaries can receive these potentially life-saving therapies in a range of settings – such as in a doctor’s office, nursing home, infusion centers, as long as safety precautions can be met. This aggressive action and innovative approach will undoubtedly save lives.”

CMS anticipates that this monoclonal antibody product will initially be given to health care providers at no charge. Medicare will not pay for the monoclonal antibody products that providers receive for free but this action provides for reimbursement for the infusion of the product. When health care providers begin to purchase monoclonal antibody products, Medicare anticipates setting the payment rate in the same way it set the payment rates for COVID-19 vaccines, such as based on 95% of the average wholesale price for COVID-19 vaccines in many provider settings. CMS will issue billing and coding instructions for health care providers in the coming days.

CMS anticipates the announcement will allow for a broad range of providers and suppliers, including freestanding and hospital-based infusion centers, home health agencies, nursing homes, and entities with whom nursing homes contract, to administer this treatment in accordance with the EUA, and bill Medicare to administer these infusions.

Under section 6008 of the Families First Coronavirus Response Act (FFCRA), state and territorial Medicaid programs may receive a temporary 6.2 percentage point increase in the Federal Medical Assistance Percentage (FMAP), through the end of the quarter in which the COVID-19 PHE ends. A condition for receipt of this enhanced federal match is that a state or territory must cover COVID-19 testing services and treatments, including vaccines and their administration, specialized equipment, and therapies for Medicaid enrollees without cost sharing. This means that this monoclonal antibody infusion is expected to be covered when furnished to Medicaid beneficiaries, in accordance with the EUA, during this period, with limited exceptions. 

View the Monoclonal Antibody COVID-19 Infusion Program Instruction.

They’re Back: Harvard Study & PatientPoint Research Show Outpatient Visits Return To Pre-Pandemic Numbers

Messages on waiting room screens continue to deliver important public health imperatives to patients, family and caregivers. In the spring, as coronavirus cases surged, research showed visits to health care providers dropped roughly 60%. But now, eight months into the pandemic, a Harvard study of more than 50 million visits across the U.S., finds patients roaring back.

“In contrast to early on in the pandemic, when patients were very scared about going to their doctor’s office, now into mid-October, the data really highlight that a lot of that fear has dissipated,” said Dr. Ateev Mehrotra, lead author of the study and an associate professor at Harvard Medical School.

The Harvard study completely corroborates PatientPoint’s findings based on medical claims data and primary research. We also found that waiting room traffic continues to grow, nearing pre-COVID levels in most of the county. Overall, we’re seeing 87% of patients are spending time in the waiting room for an average of 11 minutes per office visit.



  • Patients are back in physician offices after a low in April 2020.
  • Physician practices are encouraging patients to reschedule previously postponed visits.
  • Consumers’ concerns about risks associated with in-person visits continue to drop.
  • Patients and caregivers are spending time in waiting rooms – an average of 11 minutes.
  • The waiting room screens provide an opportunity for public health departments to reach consumers
    in a trusted, captive environment.
  • Public health messages on screens are believed to be endorsed by the consumer’s personal physician.

Funding Opportunity: Building Workforce Capacity of Rural and Frontier Local Health Departments to Respond to COVID-19

The National Association of City and County Health Officials (NACCHO) is offering the Building Workforce Capacity of Rural and Frontier Local Health Departments to Respond to COVID-19. Awards of up to $35,000 will support one of two focus areas: contact tracing and testing, or vaccine administration. Applications are due November 30, 2020.

Webinar: Navigating the Opioid Crisis Amidst a Pandemic

Date: November 13, 2020

Time: 12:00 PM Central


Drug overdose deaths are at epidemic levels in the United States. As communities work to combat this complex issue, coalitions are often expected to lead the way. This issue can take coalitions into areas beyond prevention, to address harm reduction, overdose prevention, naloxone distribution
and more.

During this first session of a two-part series, we will take a deep look at the Opioid Continuum of Care (e.g., prevention, intervention, treatment and aftercare) and discuss the unique characteristics of each stage, plus COVID-19’s impact on the crisis. Participants will examine the role of their coalitions in the opioid crisis and ways they can engage community partners and members during the pandemic.

Rural Health Clinics Increase Access to COVID-19 Testing

As COVID-19 swept across America, Congress and the Trump Administration quickly recognized that Rural Health Clinics (RHCs) would be an important source of testing for the new virus. In early May, Congress approved a $225 Million RHC COVID-19 Testing Program so all RHCs could assist with a national effort to increase COVID-19 testing.

The Federal Office of Rural Health Policy (FORHP) was charged with organizing the distribution of this money to RHCs. Through an unprecedented level of collaboration between FORHP, the National Association of Rural Health Clinics (NARHC) and the National Organization of State Offices of Rural Health (NOSORH), this money began flowing to virtually every RHC in the country in a matter of weeks.

Join the leaders of NARHC, NOSORH and FORHP as they discuss both the triumphs of RHCs during COVID-19 and the challenges ahead as we head into a winter resurgence in cases. After brief remarks from each of the rural health leaders, the lines will be opened for you to ask questions and share your experiences with the panelists and attendees. They want to hear about your success as well as what challenges you continue to face in meeting the healthcare needs of your communities in these challenging times.

This Town Hall will also serve as a kick-off to a week-long celebration of the Power of Rural culminating in National Rural Health Day on November 19th! 

Date of Webinar: Monday, November 16th, 2020
Time: 1:00 PM Central

Hosted by the leaders of NARHC, NOSORH, and FORHP


  • Tom Morris, MPA, Associate Administrator for Rural Health Policy, HRS, HHS
  • Lindsey Nienstedt, MPH, MSW, Public Health Analyst, FORHP, HHS
  • Bill Finerfrock, Executive Director of NARHC
  • Teryl Eisinger, Executive Director of NOSORH

This webinar is being provided free of charge. However, you must register in advance. If you have issues registering and are using Internet Explorer, try using another browser. If you continue to have issues, please contact us and we will assist you, 866.306.1961.  

To register, go to: https://attendee.gotowebinar.com/register/546882101207560208 or http://bit.ly/RHCs_Increase_COVID_Testing

When the webinar begins you will be connected to audio using your computer’s speakers.

A copy of the slides and a recording will be available within a few days after the webinar is complete at: https://www.narhc.org/narhc/TA_Webinars1.asp

If you have any questions about registering please email us at asst@narhc.org.

IFC-4 and COVID-19 Vaccine Toolkits Listening Session Invitation

On October 28, 2020, the Centers for Medicare & Medicaid Services (CMS) issued an Interim Final Rule with Comment Period (IFC) that removes administrative barriers to eliminate potential delays to patient access to a lifesaving vaccine. In addition, the rule:

  • Creates flexibilities for states maintaining Medicaid enrollment during the COVID19 PHE;
  • Establishes enhanced Medicare payments for new COVID-19 treatments;
  • Takes steps to ensure price transparency for COVID-19 tests, and
  • Provides an extension of Performance Year 5 for the Comprehensive Care for Joint Replacement (CJR) model; and
  • Creates flexibilities in the public notice requirements and post-award public participation requirements for a State Innovation Waiver under Section 1332 of the Patient Protection and Affordable Care Act during the COVID-19 PHE.

The CMS Kansas City office is hosting two 1-hours conversations with sessions CMS staff regarding IFC-4 and the COVID-19 Vaccine Toolkits. They will provide a brief overview of IFC-4 and look at the resources available in the COVID-19 Vaccine Toolkits. Following the overview, the lines will open up to answer questions and listen to feedback.  Information presented will be the same at both sessions; however, the listening portion will be unique to each session.

To register for the November 9 session from 10:00 – 11:00 AM CST, please click on the link here: https://www.eventbrite.com/e/registration-cms-kc-ifc-4-covid-19-vaccine-toolkits-listening-session-tickets-127913156695

To register for the November 10 session from 4:00 – 5:00 pm CST, please click on the link here: https://www.eventbrite.com/e/registration-cms-kc-ifc-4-covid-19-vaccine-toolkits-listening-session-tickets-127927874717

Register for the session that works best for you or both if you are interested in hearing questions and feedback during both sessions. After you register, you will be provided a link to access your session(s). It is strongly encouraged to review the IFC and toolkit prior to the conversation. The IFC can be found at https://www.cms.gov/files/document/covid-vax-ifc-4.pdf and the toolkits can be found at https://www.cms.gov/covidvax.

Rural Health Clinic COVID-19 Reporting Portal

On November 4,  the Health Resources and Services Administration (HRSA) posted new Frequently Asked Questions (FAQs) to assist Rural Health Clinics with recent RHC COVID-19 Testing Program reporting requirements www.hrsa.gov/rural-health/coronavirus/…. HRSA also reorganized existing FAQs for clarity and ease of use. As a reminder, funded RHCs must continue to report COVID-19 tests and spending categories monthly on the Rural Health Clinic COVID-19 Reporting Portal. October data is due by November 30. 

States Turn to Telehealth During the Pandemic

Since March, 36 states, the District of Columbia and Puerto Rico have enacted more than 79 bills changing telehealth policies, either permanently or temporarily, during the pandemic. This article published by the National Conference of State Legislatures discusses the details of that legislation. The article was funded through HRSA’s cooperative agreement with the National Organizations of State and Local Officials.

Read the article.