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CMS accepts applications for hardship exceptions

The MIPS Extreme and Uncontrollable Circumstances Exception and MIPS Promoting Interoperability Performance Category Hardship Exception applications are now open for the 2022 performance year. Applications can be submitted until Dec. 31.

MIPS Extreme and Uncontrollable Circumstances Exception Application

Merit-based Incentive Payment System (MIPS) eligible clinicians, groups, and virtual groups may apply to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances. 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 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.

CMS continues to use its extreme and uncontrollable circumstances policy to allow clinicians, groups, virtual groups, and APM Entities to submit an application requesting reweighting of performance categories for the 2022 performance year due to the COVID-19 public health emergency.

For APM entities

Alternative Payment Model (APM) entities participating in MIPS APMs can also submit a MIPS Extreme and Uncontrollable Circumstances Exception Application. However,  the following differences exist for APM Entities from the MIPS EUC 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.

Learn more in the 2022 MIPS Extreme and Uncontrollable Circumstances Application Guide.

MIPS Promoting Interoperability Performance Category Hardship Exception Applications

MIPS eligible clinicians, groups, and virtual groups may apply to reweight the Promoting Interoperability performance category to 0% if they:

  • 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 certified EHR technology (CEHRT); simply lacking the required CEHRT doesn’t qualify you for reweighting.

NOTE: You don’t need to apply for this application if you qualify for automatic reweighting of the Promoting Interoperability performance category based on your clinician type or special status.

  • Small practices qualify for automatic reweighting beginning with the 2022 performance year.
  • Refer to p. 16 of the 2022 MIPS Promoting Interoperability User Guide for a complete list of clinician types and special statuses that qualify for automatic reweighting in the 2022 performance year.

Learn more in the 2022 Promoting Interoperability Hardship Application Guide.

How do I apply?

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, virtual group or APM Entity. 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 the QPP website, 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?

You’ll be notified by email if your request was approved or denied.  You can also check the status of your application by signing into the QPP website and navigating to Exceptions. If approved, this information will also be added to your eligibility profile in the QPP Participation Status Tool on a rolling basis. If your application is approved at the end of the performance year, it may not appear in the QPP Participation Status Tool until the submission window is open in 2023.









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