About Hardship Exceptions
2017 Quality Payment Program Hardship Exception Application Overview
Certified electronic health record technology (CEHRT) is required for participation in the advancing care information performance category of the Quality Payment Program (QPP). Under Merit-based Incentive Payment System (MIPS) scoring, MIPS-eligible clinicians and groups may qualify for a reweighting of their advancing care information performance category score to 0 percent of the final score if they meet the criteria outlined below. The 25 percent weighting of the advancing care information performance category would be reallocated to the quality performance category. Simply lacking CEHRT does not qualify the MIPS-eligible clinician or group for reweighting. MIPS-eligible clinicians and groups that are participating in a MIPS Alternative Payment Model may be exempted from reporting information for the advancing care information performance category if they meet the criteria outlined below:
A MIPS-eligible clinician or group may submit a Quality Payment Program Hardship Exception Application, citing one of the following specified reasons for review and approval:
- Insufficient Internet Connectivity
- Extreme and Uncontrollable Circumstances
- Lack of Control over the availability of CEHRT
Special Status Clinicians
There are some MIPS-eligible clinicians that are considered Special Status, who will be automatically reweighted (or exempted in the case of MIPS-eligible clinicians participating in a MIPS APM) and do not need to submit a Quality Payment Program Hardship Exception Application.
For 2017, Special Status clinicians include the following:
- Hospital-based MIPS-eligible clinicians
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Non-patient facing clinicians
- PROPOSED in Quality Payment Program Year 2 (82 FR 30077):
Ambulatory Surgical Center (ASC) Based MIPS-Eligible Clinicians
- Note: The ASC-Based MIPS-Eligible Clinicians policy is proposed to apply beginning with the 2017 transition year. The definition of ASC-based MIPS-eligible clinician and the reweighting policy will be established in the upcoming 2018 Quality Payment Program Year 2 Final Rule.
A group’s advancing care information performance category score is automatically reweighted, (or exempted in the case of groups participating in a MIPS Alternative Payment Model (APM)), and the group would not need to submit a Quality Payment Program Advancing Care Information Hardship Exception Application if all of their MIPS-eligible clinicians within the group receive a hardship exception or fall into one or more of the Special Status categories above, with the exception of a non-patient facing group which only requires that 75 percent of clinicians are non-patient facing.
In addition, a group is automatically reweighted (or exempted) and does not need to submit a Quality Payment Program Hardship Exception Application if it is non-patient facing. Groups are considered non-patient facing if more than 75 percent of its clinicians have 100 or fewer patient-facing encounters (including Medicare telehealth services).
If all of the MIPS-eligible clinicians within a group do not qualify for an automatic reweighting or do not submit an application for and receive a hardship exception, the group will not qualify for an automatic reweighting and will have to report on the advancing care information performance category.
The Quality Payment Program Hardship Exception Application
The Quality Payment Program Hardship Exception Application for the 2017 transition year will open on August 2, 2017. Clinicians may also contact the Quality Payment Program Service Center and work with a representative to verbally submit an application. Applications are subject to annual renewal.
To streamline the process, the application is available to both individual clinicians and groups.
To submit your application, you’ll need:
- Your Taxpayer Identification Number (TIN) or National Provider
- NPI for Individual Applications
- Group TIN for Group Applications
- Contact information from person working on behalf of the
individual clinician or group:
- Submitter First Name
- Submitter Last Name
- Submitter Email Address (This is how we will communicate with you.)
- Submitter Business Telephone Number (Include area code)
- Submitter Extension
- Select the hardship exception category and supplemental
- Insufficient Internet Connectivity
- Extreme and Uncontrollable Circumstances
- Lack of Control over the Availability of CEHRT
- If you are applying for a hardship exception based on Extreme
and Uncontrollable Circumstance category, you must select one of
the following and provide a start and end date of when the
- Disaster (i.e. a natural disaster in which the CEHRT was damaged or destroyed)
- Practice or Hospital Closure
- Severe Financial Distress (Bankruptcy or debt restructuring)
- EHR Certification/Vendor Issues (CEHRT issues)
- If your product was decertified, you must provide the Certification Number
Once the application is submitted, you will receive a confirmation email that your application was submitted and is in a pending, approved, or dismissed status. Applications will be processed on a rolling basis.
Please note: if using Internet Explorer:
- Setting Security Mode to High (via Internet Options > Security tab) is not supported
- There is a known issue where some icons may not appear. When
hovering over the area where the icons should be, the
hover-over help is displayed. When clicking into the area,
the functionality is executed as if the icon were there.
Either of the possible fixes may need System Admin privilege
to make the change:
- Add the name of your instance (https://qppprod.service-now.com) to the trusted sites in Internet Explorer and the icons will appear.
- Change a browser setting to allow download of external fonts
Frequently Asked Questions
- If I submit a hardship exception application, does that mean that I cannot report on the advancing care information performance category for 2017 performance period?
- No. You may still report on the advancing care information performance category, and if you choose to report, your data will be scored. If you have a pending or approved hardship exception application and choose to report on the advancing care information measures, your hardship exception application will be dismissed.
- If I have received a hardship exception for the advancing care information performance category, do I still need to report on the advancing care information performance category if I am participating in a MIPS APM?
If you have received a hardship exception, you are not required to report on this performance category. We have proposed a policy for addressing hardship exceptions for advancing care information under the APM scoring standard in the Quality Payment Program Year 2 NPRM (82 FR 30010), which, if finalized, would be applied beginning with the 2017 performance period and reweight the ACI performance category to 0 percent, as appropriate and the category weight allocated to the quality performance category.
Please note, however, that the MIPS hardship exception does not exempt you from reporting on any CEHRT activities required for participation in your APM.
- Will CMS require the submission of supporting documentation along with the hardship exception application?
- CMS does not require a MIPS-eligible clinician or group to submit documentation with the exception application. CMS will review the application to record the category selected and use the identifying information for each clinician and group listed on the application. Clinicians and groups should retain documentation of their circumstances supporting their application for their own records in the event CMS requests data validation or audit.
- If a practice has multiple office locations under the same TIN, and one office is within a broadband availability area but the other office for the practice is not, would that practice still qualify for the hardship exception (Same TIN)?
- No, the office with broadband availability would not qualify for the hardship exception and, if a practice has an office site with sufficient internet access, the group must report for those clinicians for whom they have data.
- Can MIPS-eligible clinicians that have switched CEHRT vendors apply for a hardship exception and have their advancing care information performance category weight reallocated to the quality performance category?
- Yes, if a MIPS-eligible clinician switches CEHRT vendors during the performance period and is unable to demonstrate meaningful use, the clinician may apply for an Extreme and Uncontrollable Circumstances hardship exception. For example, if a MIPS-eligible clinician switches CEHRT vendors in 2017 and is unable to submit measures for the advancing care information performance category for the 2017 performance period, the MIPS-eligible clinician can apply for an Extreme and Uncontrollable Circumstance category hardship exception, before the submission deadline.
- What if my electronic health record (EHR) product is decertified?
- If your EHR product is decertified, you can still use that product to submit your advancing care information performance category measures if your performance period ended before the decertification occurred. If your performance period ended after the decertification occurred, you can apply for a hardship exception.
Questions? Contact the Quality Payment Service Center at 1-866-288-8292 or TTY: 1-877-715-6222 or QPP@cms.hhs.gov.