Posted on August 15, 2018
MIPS Hardship Exceptions
MIPS eligible clinicians and groups can now apply for the 2018 Promoting Interoperability (PI) Hardship Exception or the MIPS Program Extreme and Uncontrollable Circumstances Exception. Exceptions will be available to those who meet certain criteria established by CMS.
Who Qualifies for a PI Hardship Exception?
Clinicians and groups must have 2014 or 2015 Certified Electronic Health Record Technology (CEHRT) to participate in the MIPS PI category in 2018. The PI category is worth 25% of the total MIPS score, but some clinicians may qualify to have it reweighted to 0. In this case, the 25% weighting would be reallocated to the Quality category.
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:
- MIPS eligible clinicians in small practices (15 or less providers under the Tax Identification Number) - NEW for 2018
- MIPS eligible clinicians using de-certified EHR technology - NEW for 2018
- Insufficient Internet connectivity
- Extreme and uncontrollable circumstances
- Lack of 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 that are considered Special Status will be automatically reweighted (or exempted in the case of MIPS-eligible clinicians participating in a MIPS APM) and are not required to submit a hardship exception application. For 2018, these 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 PI score is reweighted automatically and would not need to submit an 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. An exception to this is a non-patient facing group (groups where more than 75% of their clinicians have 100 or fewer patient facing encounters). A non-patient facing group is automatically reweighted and does not need to submit an exception application.
CMS has explained that if all MIPS eligible clinicians in a group do not qualify for automatic reweighting, or do not apply for and receive a hardship exception, the group would not qualify for automatic reweighting and would have to report the PI category.
Extreme and Uncontrollable Circumstances
If a MIPS eligible clinician or group is impacted by an extreme and uncontrollable circumstance, 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 (highly unlikely to occur in a given year) that are outside of your control and the facility in which you practice. 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 2018 MIPS performance period.
How to Apply
The application is available on the QPP website to both clinicians and groups and must be submitted by December 31, 2018. You can click on the link below to complete the application online or call the QPP Service Center at 1-866-288-8292 to submit a verbal application.
Apply for an Exception Online
In order to prepare for submitting the application, clinicians and groups should have certain information readily available:
- Your Tax Identification Number (TIN) for group applications or your National Provider Identifier (NPI) for individual applications
- Contact information for the person working on behalf of the clinician or group
- For Extreme and Uncontrollable Circumstances, a start and end date of when the circumstance occurred
MIPS eligible clinicians and groups who are interested in submitting a hardship exception application should do so before the CMS deadline on December 31, 2018. Applicants will receive an email confirmation that the application was submitted and is in a pending, approved or dismissed status. 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 Hardship Exception Process Promoting Interoperability Extreme and Uncontrollable Circumstances