2019 MIPS Exception Application Period Announced

September 2019 ~

Last year, the 2018 final rule for the Medicare Quality Payment Program (QPP) included a new opportunity for small practices to waive participation in the Merit-based Incentive Payment System (MIPS) Promoting Interoperability (PI) performance category. This exception is available, again, in 2019.

The Promoting Interoperability Hardship Exception, previously known as Meaningful Use, performance category grades physicians on their “electronic exchange of health information using certified electronic health record technology (CEHRT).”

CMS is offering clinicians who cannot meet some MIPS program requirements an opportunity to apply for exceptions if they meet certain criteria. A PI Hardship Exception application can be submitted if any of the following apply:

• Practices with 15 or fewer clinicians
• Practices with decertified electronic health record (EHR) technology
• Practices with insufficient internet connectivity
• Practices facing extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
• Practices lacking control over the availability of CEHRT

Special Status

Prior to submitting an application, practices and providers should check to see if they are already exempt from the PI category based on a “Special Status” designation. MIPS-eligible clinicians that are considered Special Status will be automatically reweighted and are not required to submit a hardship exception application.

For 2019, these Special Status clinicians include the following:

• Hospital-based MIPS eligible clinicians
• Non-Patient Facing clinicians
• Ambulatory Surgical Center (ASC)— based MIPS eligible clinicians
• Nurse practitioners, physician assistants, clinical nurse specialists, certified registered nurse anesthetists
• Physical therapists, occupational therapists, speech-language pathologists, audiologists, clinical psychologists and registered dietitians and nutrition professionals (newly added to the program in 2019)

Extreme and Uncontrollable Circumstances Exception
In situations where a MIPS eligible clinician or group has been impacted by an extreme and uncontrollable circumstance, providers may submit a request for reweighting of the Quality, Cost, Improvement Activities and/or the PI performance categories.

These circumstances would cause providers to either be 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 (for example, if providers are unable to collect data for the Quality performance category for 3 months).

The two exception applications are now available and can be submitted through December 31, 2019.

To apply, access the Hardship Exception application and the MIPS Extreme and Uncontrollable Circumstances application on the QPP website. CMS will notify clinicians via email if their application is approved or denied.

All approvals will be added to the providers eligibility profile in the QPP Participation Status lookup tool when the submission window opens in 2020.

For more information on the Promoting Interoperability Hardship Exception, see the 2019 Exceptions FAQs.

Source(s): 2019 Exceptions FAQs; AAPS Online; MIPS Blog; Quality Insights QPP Support Center;