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Quality Payment Program (QPP) Support Center

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2019 MIPS Exception Applications Are Now Available

8/22/2019

The Centers for Medicare & Medicaid Services (CMS) offers clinicians who cannot meet some Merit-based Incentive Payment System (MIPS) program requirements an opportunity to apply for exceptions if they meet certain criteria. The two exception applications are now available and can be submitted through December 31, 2019.
Promoting Interoperability (PI) Hardship Exception
A PI Hardship Exception application can be submitted if any of the following apply:
  • You're a small practice (15 or fewer clinicians)
  • You have decertified electronic health record (EHR) technology
  • You have insufficient internet connectivity
  • You face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
  • You lack control over the availability of certified electronic health record technology (CEHRT)
If the application is approved, you will not have to report PI data, the PI category will be re-weighted to zero, and your quality category weight will be increased to 70%. If PI data is submitted after an exception application has been approved, the data will be scored, the re-weighting will be removed, and the PI category will be worth 25% of the final MIPS score.
 
All clinicians will be notified by email if their application is approved or denied. If approved, it will be added to your eligibility profile in the QPP Participation Status lookup tool when the submission window opens in 2020. Apply now.
 
*Please remember that approval of the PI Hardship Exception application is only applicable to the PI category. You must still report data for the other categories and achieve a minimum MIPS score of 30 points this year to avoid a 7% penalty.
 
The following clinician types qualify for automatic reweighting of the PI category in 2019: non-patient facing, hospital-based, ASC-based, PA, NP, CNS, CRNA, PT, OT, RD, SLP, clinical psychologists, qualified audiologists, and nutrition professionals. If PI data is submitted by a clinician, it will be scored.
 
Extreme and Uncontrollable Circumstances Exception
MIPS 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 are 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.
 
All clinicians will be notified by email if their application is approved or denied. If approved, it will be added to your eligibility profile in the QPP Participation Status lookup tool when the submission window opens in 2020. If your application is approved, you do not have to report data for the requested category or categories, and those categories will be re-weighted. If data is submitted for at least two categories after an exception application has been approved, it will be scored, and result in the calculation of a MIPS score.
 
Clinicians do not need to submit an extreme and uncontrollable circumstance exception application if they are located in a CMS-designated region that has been affected by an extreme and uncontrollable event, such as FEMA-designated major disasters like hurricanes and fires. The automatic extreme and uncontrollable circumstances policy is applied to those clinicians and they will have all four performance categories re-weighted to 0%, unless they choose to submit data for two or more performance categories. Apply now.
 
Learn more by reviewing the 2019 Exceptions FAQs