About QPP Exceptions

We understand that there may be circumstances out of your control that make it difficult for you to meet program requirements. To reduce this burden, you have the opportunity to apply for exceptions to meeting MIPS program requirements. In certain circumstances, these exceptions may be applied automatically.  QPP exception guidelines may change each Performance Year (PY) due to policy changes. For PY 2019, you can apply for either the Promoting Interoperability Hardship Exception or the Extreme and Uncontrollable Circumstances Exception.

Promoting Interoperability Hardship Exception

Certified electronic health record technology (CEHRT) is required for participation in the Promoting Interoperability performance category. Under the Merit-based Incentive Payment System (MIPS), you may qualify for a re-weighting of the Promoting Interoperability performance category (to 0%) if you meet certain criteria.

Can I Apply for a PI Hardship Exception?

MIPS eligible clinicians, groups, and virtual groups may submit a Promoting Interoperability Hardship Exception Application citing one of the following specified reasons:  you’re a small practice, you have decertified EHR technology, you have insufficient Internet connectivity, you face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues, or you lack control over the availability of CEHRT.  Lacking CEHRT does not qualify you for re-weighting. Take note that if you’re already exempt from submitting Promoting Interoperability, you don’t need to apply for this application.

How Do I Apply?

The Promoting Interoperability Hardship Exception Application for the Performance Year 2019 will open early summer 2019 and close December 31, 2019.

How Do I Know if I’m Approved?

You’ll be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile in the QPP Participation Status lookup tool, but may not appear in the lookup tool until the submission window is open in 2020.

What Happens if my Application is Approved?

If your application is approved, you do not have to report for the Promoting Interoperability performance category and the category will be re-weighted to 0% of your final score.  The 25% weighting of the Promoting Interoperability performance category will be reallocated to the Quality performance category.

What Should I do If I’m an APM Participant?

MIPS eligible clinicians and Taxpayer Identification Numbers (TINs) participating in a MIPS Alternative Payment Model (APM) do not need to report data for the Promoting Interoperability performance category if they qualify for automatic re-weighting or have an approved hardship exception. However, these clinicians will receive the APM entity score for Promoting Interoperability as determined by the APM scoring standard if the performance category is not reweighted for the entire entity.  MIPS eligible clinicians who are scored under the APM Scoring Standard receive the APM entity’s Promoting Interoperability score. If these clinicians qualify for re-weighting at the individual or TIN level, they will be assigned a null value when calculating the average score for the APM entity.

Can I Still Submit Data?

Yes. Whether you qualify for automatic re-weighting or have an approved exception application, you can still choose to report. If you do submit data, CMS will score your performance and weight your Promoting Interoperability performance at 25% of your MIPS final score. (Note: You will be scored in this performance category if you attest to any data, including your performance period.)

Extreme and Uncontrollable Circumstances Exception

MIPS eligible clinicians, groups, and virtual groups may submit an application for re-weighting of any or all MIPS performance categories if they’ve been impacted by extreme and uncontrollable circumstances that extend beyond the Promoting Interoperability performance category.

Can I Apply for an Extreme and Uncontrollable Circumstances Exception?

Extreme and uncontrollable circumstances are defined 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 unable to submit information that would be used to score a 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).

When Does This Exception get Applied Automatically?

The automatic extreme and uncontrollable circumstances policy applies to MIPS eligible clinicians who are located in a Centers for Medicare & Medicaid Services (CMS)-designated region that has been affected by an extreme and uncontrollable event (such as FEMA-designated major disaster) during the 2019 MIPS performance period.  The automatic extreme and uncontrollable circumstances policy does not apply to group or virtual group participation. MIPS eligible clinicians identified as affected by the automatic extreme and uncontrollable policy will have all four performance categories re-weighted to 0% of their final score unless they submit data for two or more performance categories.

How Do I Apply?

The Extreme and Uncontrollable Circumstances Application for the Performance Year 2019 will open early summer 2019 and close December 31, 2019.

How Do I Know if I’m Approved?

You’ll be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile in the QPP Participation Status Tool, but may not appear in the lookup tool until the submission window is open in 2020.

What Happens if My Application is Approved?

If your application is approved, you do not have to report for the requested performance category or categories, and those categories will be re-weighted.

Can I Still Submit Data?

Yes. Whether you qualify for automatic re-weighting or have an approved exception application, you can still choose to report. If you submit data for two or more performance categories, you’ll receive a final score based on your performance in these categories.

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