In response to the national intravenous (IV) fluid shortage, the Centers for Medicare & Medicaid Services (CMS) has announced that it will reopen the 2024 MIPS Extreme and Uncontrollable Circumstances (EUC) Exception Application to provide relief to affected practices.
The Merit-based Incentive Payment System (MIPS) is a CMS quality payment program that adjusts Medicare payments based on clinicians’ performance across quality, cost, promoting interoperability, and improvement activities. CMS allows clinicians to apply for exceptions to meet MIPS program requirements when circumstances beyond their control—such as the IV fluid shortage—make compliance difficult. The EUC policy recognizes that such situations may prevent clinicians from fully participating in MIPS and provides a pathway for relief.
Specifically, physicians will be able to submit an EUC hardship exception application between March 31- April 14, to avoid a MIPS penalty of up to -9% if they were affected by the shortage. This hardship exception will apply to the 2024 performance period, which will adjust Medicare payments in 2026. To avoid a MIPS penalty, physicians who were affected by the IV fluid shortage should submit an EUC application requesting reweighting of all four MIPS categories – quality, cost, promoting interoperability, and improvement activities. We encourage you to check with your institution to confirm whether you are eligible and if they plan to submit an application on your behalf. You can find more information about this opportunity here. Please don’t hesitate to reach out with any questions.