MIPS eligible clinicians, groups and virtual groups can now apply for the 2020 Promoting Interoperability (PI) Hardship Exception or the MIPS Program Extreme and Uncontrollable Circumstances Exception. Applications must be submitted to CMS by December 31, 2020. Exceptions will be available to those who meet certain criteria established by CMS. Those who qualify for automatic reweighting of PI reporting do not need to apply for this exception.
Promoting Interoperability (PI) Hardship Exception
Clinicians and groups must have 2015 Certified Electronic Health Record Technology (CEHRT) to participate in the MIPS PI category in 2020. The PI category is worth 25% of the total MIPS score, but some clinicians may qualify to have it reweighted to zero (0). In this case, the 25% weighting would be reallocated to the Quality category.
Who Qualifies for a PI Hardship Exception?
According to CMS, simply lacking CEHRT does not qualify for reweighting. Instead, a hardship exception application could be submitted based on one of the following 5 reasons:
- You are in a small practice (15 or less providers under the Tax Identification Number)
- You have de-certified EHR technology
- You have insufficient Internet connectivity
- You face extreme and uncontrollable circumstances
- You lack control over the availability of CEHRT
Check for Special Status
Before submitting an application, you should check to see if you are already exempt from the PI category based on a “Special Status” designation. MIPS eligible clinicians who are considered Special Status will be automatically reweighted and are not required to submit a hardship exception application.
For 2020, these Special Status clinicians include the following:
- Hospital-based MIPS eligible clinicians
- Non-Patient Facing clinicians
- Ambulatory Surgical Center (ASC)— based MIPS eligible clinicians
- Nurse practitioners, physician assistants, clinical nurse specialists, certified registered nurse anesthetists
- Physical therapists, occupational therapists, speech-language pathologists, audiologists, clinical psychologists and registered dietitians and nutrition professionals (newly added to the program in 2019)
If reporting as a group, all MIPS eligible clinicians in the group must qualify for reweighting in order for the PI category score to be reweighted for the group.
Extreme and Uncontrollable Circumstances Exception (EUC)
If a MIPS eligible clinician or group is impacted by an extreme and uncontrollable circumstance (EUC), they may submit a request for reweighting of the Quality, Cost, Improvement Activities and/or the PI performance categories. CMS defines “extreme and uncontrollable circumstances” as rare events entirely outside of your control and the control of the facility in which you practice. These circumstances would cause you to either be unable to:
- Collect information necessary to submit for a performance category, OR
- Submit information that would be used to score a performance category for an extended period (for example, if you were unable to collect data for the Quality performance category for 3 months).
If applying for this exception, you would indicate the performance categories that were subject to an extreme and uncontrollable circumstance and the impact it had on preventing the collection or submission of data for the 2020 MIPS performance period.
MIPS Performance Category Reweighting Policies for the 2020 MIPS Performance Year
CMS has prepared the table below to illustrate the 2020 performance category weights and reweighting policies that it will apply to clinicians for the MIPS 2020 performance year. If fewer than 2 performance categories can be scored (meaning 1 performance category is weighted at 100%, or all performance categories are weighted at 0%), the clinician or group will receive a final score equal to the performance threshold and they will receive a neutral payment adjustment in the 2022 payment year.
| MIPS Performance Category Reweight Scenario | Quality Category Weight | Cost Category Weight | Improvement Activities Category Weight | Promoting Interoperability Category Weight |
|---|---|---|---|---|
| No Reweighting Applies | 45% | 15% | 15% | 25% |
| Reweight 1 Performance Category | ||||
| No Cost (APM Scoring Standard) | 50% | 0% | 20% | 30% |
| No Cost | 55% | 0% | 15% | 30% |
| No Promoting Interoperability | 70% | 15% | 15% | 0% |
| No Quality | 0% | 15% | 15% | 70% |
| No Improvement Activities | 60% | 15% | 0% | 25% |
| Reweight 2 Performance Categories | ||||
| No Cost and No Promoting Interoperability | 85% | 0% | 15% | 0% |
| No Cost and No Promoting Interoperability (APM Scoring Standard) | 75% | 0% | 25% | 0% |
| No Cost and No Quality | 0% | 0% | 15% | 85% |
| No Cost and No Quality (APM Scoring Standard) | 0% | 0% | 20% | 80% |
| No Cost and No Improvement Activities | 70% | 0% | 0% | 30% |
| No Promoting Interoperability and No Quality | 0% | 50% | 50% | 0% |
| No Promoting Interoperability and No Improvement Activities | 85% | 15% | 0% | 0% |
| No Quality and No Improvement Activities | 0% | 15% | 0% | 85% |
The CMS table below illustrates the 2020 MIPS performance category reweighting policies that
CMS will apply to clinicians reporting as individuals under the MIPS automatic extreme and uncontrollable circumstances policy.
| Data Submitted | Quality Category Weight | Promoting Interoperability Category Weight | Improvement Activities Category Weight | Cost Category Weight | Payment Adjustment |
|---|---|---|---|---|---|
| No data | 0% | 0% | 0% | 0% | Neutral |
| Submit Data for One Performance Category | |||||
| Quality Only | 100% | 0% | 0% | 0% | Neutral |
| Promoting Interoperability Only | 0% | 100% | 0% | 0% | Neutral |
| Improvement Activties Only | 0% | 0% | 100% | 0% | Neutral |
| Submit Data for Two Performance Categories | |||||
| Quality and Promoting Interoperability | 70% | 30% | 0% | 0% | Positive, Negative, or Neutral |
| Quality and Improvement Activities | 85% | 0% | 15% | 0% | Positive, Negative, or Neutral |
| Improvement Activities and Promoting Interoperability | 0% | 85% | 15% | 0% | Positive, Negative, or Neutral |
| Submit Data for Three Performance Categories | |||||
| Quality and Improvement Activities and Promoting Interoperability | 55% | 30% | 15% | 0% | Positive, |
How to Apply
MDinteractive has made it easy to apply for the PI Hardship Exception directly from your MDinteractive account dashboard by following these simple steps by December 31, 2020:
1. Log into your MDinteractive account (or create a free account here).
2. Click on the red "Apply PI Hardship" under the Actions column of your dashboard (Set up your dashboard if you haven't already done so by entering your NPI and TIN, or just the TIN if you are reporting MIPS as a group).
3. Follow a few steps to complete your PI Hardship Application.
You can also apply for the Hardship Exception application and the MIPS Extreme and Uncontrollable Circumstances application directly on the QPP website by December 31, 2020. CMS will notify you by email if your request was approved or denied. Approval will also be added to your eligibility profile in the QPP Participation Status Tool.
*Important Note: Clinicians in small practices whose goal is to avoid the penalty by minimally participating in MIPS should apply for the PI Hardship in 2020 to have PI reweighted to their Quality score. In this case, you should select “Small Practice” as the reason for the PI Hardship.
In order to prepare for submitting the application, clinicians and groups should have certain information readily available:
- Individual applications: the clinician's NPI, group name, and group TIN
- Group application: group name and TIN
- Virtual group application: VG ID
More information about the exceptions process can be found on the CMS QPP website.
Final Thoughts
MIPS eligible clinicians and groups who are interested in submitting a Hardship Exception application or an Extreme and Uncontrollable Circumstances Exception application should do so before the CMS deadline on December 31, 2020. CMS extended the deadline for COVID-19 related 2020 MIPS Extreme and Uncontrollable Circumstances Exception applications to February 1, 2021. You can apply directly from your MDinteractive account dashboard or from the QPP website. It will be important for clinicians in small practices whose goal is to avoid the penalty by minimally participating in MIPS to apply for the PI Hardship to have PI reweighted to their Quality score. While CMS does not require clinicians to submit supporting documentation with their exception application, they should retain documentation of their circumstances in case CMS requests data validation or audit.
MACRA MIPS Apply for Hardship Exception Application Promoting Interoperability Extreme and Uncontrollable Circumstances
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