Applications are now open for the MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exception for the 2021 Performance Year. Those interested must submit their applications to CMS by December 31, 2021.
Who is Eligible for a Promoting Interoperability Hardship Exception?
MIPS eligible clinicians, groups, and virtual groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception Application whether they’re reporting traditional MIPS or the APM Performance Pathway. Exceptions are granted 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 submitting Promoting Interoperability data, you don’t need to apply.
For APM Participants
MIPS eligible clinicians and groups with MIPS eligible clinicians participating in a MIPS APM can apply for Promoting Interoperability hardship exceptions and qualify for automatic reweighting just like other MIPS eligible clinicians. If you’re participating as an APM entity, you will receive the APM Entity’s score, but will be excluded from the calculation when CMS creates an average Promoting Interoperability score for the APM Entity.
Who is Eligible for an Extreme and Uncontrollable Circumstances Exception?
MIPS eligible clinicians, groups, and virtual groups may submit an application to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must:
• Cause you to be unable to collect information necessary to submit for a MIPS performance category
• Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for 3 months), and/or
• Impact your normal process, affecting your performance on cost measures and other administrative claims measures
NOTE: For the 2021 Performance Year we will continue to use our extreme and uncontrollable circumstances policy to allow clinicians, groups, virtual groups, and APM Entities to submit an application requesting reweighting of performance categories due to the current COVID-19 public health emergency.
For APM Entities
APM entities participating in MIPS APMs are also able to submit an Extreme and Uncontrollable Circumstances Exception Application that includes differences from the existing policy for individual, groups, and virtual groups.
• APM Entities are required to request reweighting for all performance categories
• Additionally, at least 75% of an APM Entity’s MIPS eligible clinicians must qualify for reweighting in the Promoting Interoperability performance category
• Data submission for an APM entity will not override performance category reweighting
• Users must have the Security Official role for their organization to submit an application on behalf of an APM Entity
How do I Apply?
In order to apply you must create a HCQIS Access Roles and Profile (HARP) account to submit an Extreme and Uncontrollable Circumstances Application. For more information on how to obtain a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide, found by entering “access user guide” in the Resource Library.
• You must have the Security Official role to submit an application on behalf of an entire APPM Entity. For more information on how to obtain a Security Official role, refer to the Connect to an Organization document in the QPP Access User Guide, found by entering “access user guide” in the Resource Library.
Once you sign into QPP with your HARP credentials, click ‘Exceptions Application’ on the left-hand navigation and then select ‘Extreme and Uncontrollable Circumstances’ or ‘Promoting Interoperability Hardship.’
How do I know if I’m Approved?
If you submit an application for either exception, you’ll 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.
For More Information
Visit the MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exception QPP webpages for more information and link to the application.
Download the 2021 MIPS Promoting Interoperability Hardship Exception Application Guide and the 2021 Extreme and Uncontrollable Circumstances Exception Application Guide now available on the QPP Resource Library.
Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.
Contact the experts at Kentucky REC for all your QPP, MIPS, and APM questions. We’re here to help: 859-323-3090.