If you are interested in applying for a Merit-based Incentive Payment System (MIPS) Promoting Interoperability Hardship Exception or Extreme and Uncontrollable Circumstances Exception for the 2020 Performance Year of MIPS, you must submit your application to CMS by Thursday, December 31, 2020 at 8:00 p.m. ET.

Who is Eligible for a MIPS Promoting Interoperability Hardship Exception?

MIPS eligible clinicians, groups, and virtual groups may qualify for a re-weighting of the Promoting Interoperability performance category to 0% if they:

  • Are a small practice;
  • Have decertified EHR technology;
  • Have insufficient Internet connectivity;
  • Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues; or
  • Lack control over the availability of CEHRT.

Note: If you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply.

Who is Eligible for an Extreme and Uncontrollable Circumstances Exception?

MIPS eligible clinicians, groups, and virtual groups may qualify for a re-weighting of any or all MIPS performance categories to 0% if they are affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must render them 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 of time.
  • Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.

COVID-19 Flexibilities

The COVID-19 pandemic has impacted all clinicians across the United States and territories. However, CMS recognizes that not all practices have been impacted by COVID-19 to the same extent. For the 2020 performance year, CMS will be using our Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency. For more information, visit the QPP COVID-19 Response webpage.

Note: CMS is proposing to allow APM Entities to submit an application to reweight MIPS performance categories as a result of extreme and uncontrollable circumstances, such as the public health emergency resulting from the COVID-19 pandemic. Learn more in the 2021 Quality Payment Program Proposed Rule Overview Fact Sheet.

How do I Apply?

New for 2020: You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself, or another MIPS eligible clinician, group or virtual group. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you register for a HARP account, sign in to qpp.cms.gov, select ‘Exceptions Applications’ on the left-hand navigation, select ‘Add New Exception,’ and select ‘Extreme and Uncontrollable Circumstances Exception’ or ‘Promoting Interoperability Hardship Exception.’

How do I Know if I’m Approved?

If you submit an application for either of the exceptions, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but may not appear in the tool until the submission window is open in 2021.

For More Information

Questions?

Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.

  • Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

About Author

Healthcentric Advisors
As the New England Quality Payment Program Support Center, Healthcentric Advisors assists New England-based physician and other eligible clinical practices to prepare for and participate in the new Quality Payment Program (QPP), established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).