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MIPS-eligible clinicians looking to apply for the hardship exception from the Promoting Interoperability (formerly Advancing Care Information) category can now submit their applications.
The hardship exception, if approved, would allow individual clinicians and groups to re-weight the Promoting Interoperability performance category to 0% of their MIPS score. The Quality performance category would absorb this weight and be revalued at 70% of the participant’s final score.
This exception is not open to just anyone, however. Simply not having CEHRT does not qualify you/your group for re-weighting. The participant will have to cite at least one of the following reasons to qualify for the exception:
- The MIPS-eligible clinician is a small practice (15 or fewer clinicians)
- The MIPS-eligible clinician uses decertified EHR technology
- Insufficient internet connectivity
- Extreme and uncontrollable circumstances
- Lack of control over the availability of CEHRT
Approval is subject to a CMS review and determination of validity. Applications must be submitted by December 31, 2019. If you’ve submitted a hardship exception application and received your approval via email, you may not see the re-determination reflected in your QPP account until next summer when MIPS 2019 scores are published by CMS. If you have not received your approval email but believe you should, contact the QPP help desk at QPP@cms.hhs.gov.
Some MIPS participants will NOT need to submit the hardship exception application to have their Promoting Interoperability category re-weighted. These include:
- 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
These participants considered ‘Special Status’, and their Promoting Interoperability category will be automatically re-weighted without submitting the hardship exception applications. However, Special Status clinicians can still report for the Promoting Interoperability category! If any Promoting Interoperability data is reported, the automatic re-weighting will be overridden, and the clinician(s) will be scored according to the default weight of 25% of their final score.
Note: If a special status clinician is reporting MIPS as a group with other non-Special Status clinicians, they will lose their automatic re-weighting.
Hardship exception applications are available at QPP Exception Applications. Verbal submission of applications is also permitted by calling the QPP Center at 1-866-288-8292.