Certified electronic health record technology (CEHRT) is required for participation in the Promoting Interoperability performance category of the Quality Payment Program (QPP). Under Merit-based Incentive Payment System (MIPS) scoring, MIPS-eligible clinicians and groups may qualify for a reweighting of their Promoting Interoperability performance category score to 0 percent of the final score if they meet the criteria outlined below. The 25 percent weighting of the Promoting Interoperability performance category would be reallocated to the Quality performance category. Simply lacking CEHRT does not qualify the MIPS-eligible clinician or group for reweighting. MIPS-eligible clinicians and groups that are participating in a MIPS Alternative Payment Model may be exempted from reporting information for the advancing care information performance category if they meet the criteria outlined below:
A MIPS-eligible clinician or group may submit a Quality Payment Program Hardship Exception Application, citing one of the following specified reasons for review and approval:
- MIPS-eligible clinicians in small practices (New for 2018)
- MIPS-eligible clinicians using decertified EHR technology (New for 2018)
- Insufficient Internet connectivity
- Extreme and uncontrollable circumstances
- Lack of control over the availability of CEHRT
Special Status Clinicians
There are some MIPS-eligible clinicians that are considered Special Status, who will be automatically reweighted (or exempted in the case of MIPS-eligible clinicians participating in a MIPS APM) and do not need to submit a Quality Payment Program Hardship Exception Application.
For 2018, Special Status clinicians include the following:
- Hospital-based MIPS-eligible clinicians
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Non-patient facing clinicians
- Ambulatory Surgical Center (ASC) Based MIPS-Eligible Clinicians
A group’s Promoting Interoperability performance category score is automatically reweighted, (or exempted in the case of groups participating in a MIPS Alternative Payment Model (APM)), and the group would not need to submit a Quality Payment Program Promoting Interoperability Hardship Exception Application if all of their MIPS-eligible clinicians within the group receive a hardship exception or fall into one or more of the Special Status categories above, with the exception of a non-patient facing group which only requires that 75 percent of clinicians are non-patient facing.
In addition, a group is automatically reweighted (or exempted) and does not need to submit a Quality Payment Program Hardship Exception Application if it is non-patient facing. Groups are considered non-patient facing if more than 75 percent of its clinicians have 100 or fewer patient-facing encounters (including Medicare telehealth services).
If all of the MIPS-eligible clinicians within a group do not qualify for an automatic reweighting or do not submit an application for and receive a hardship exception, the group will not qualify for an automatic reweighting and will have to report on the Promoting Interoperability performance category.