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About Exception Applications

We understand that there may be circumstances, out of your control, that make it difficult for you to meet program requirements. We provide the opportunity to apply for Exceptions for MIPS (all performance categories) or the Promoting Interoperability performance category only.

Exception Applications may change each Performance Year (PY) due to shifting requirements.

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 Performance Year 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
  • Ambulatory Surgical Center (ASC)-based MIPS-eligible clinicians

A group’s Advancing Care Information performance category score is automatically reweighted, (or excepted in the case of clinicians or groups participating in a MIPS Alternative Payment Model (APM)), and the clinician or 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 excepted) 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 their 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.

What Exceptions Can I Apply For?

For PY 2018, you can apply for either the Promoting Interoperability Hardship Exception or the Extreme and Uncontrollable Circumstances Exception.

Promoting Interoperability Hardship Exception Overview

Certified electronic health record technology (CEHRT) is required for participation in the Promoting Interoperability (formerly 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 Promoting Interoperability performance category score to 0 percent of the final score if you meet the criteria. The 25 percent weighting of the Promoting Interoperability performance category would be reallocated to the Quality performance category.

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 (APM) may be excepted from reporting information for the Promoting Interoperability performance category if they meet the criteria.

MIPS-eligible clinicians or groups may submit a Quality Payment Program Exception Application citing one of the following specified reasons for review and approval:

  • MIPS-eligible clinicians in small practices
  • MIPS-eligible clinicians using decertified EHR technology
  • Insufficient Internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of CEHRT

If you are a MIPS-eligible clinician, you must submit an application by December 31, 2018 for CMS to reweight the Promoting Interoperability performance category to 0 percent. The application will be available from August 6, 2018 - December 31, 2018.

Special Status Clinicians

Some MIPS-eligible clinicians that are considered Special Status will be automatically reweighted (or exempted as in the case of MIPS-eligible clinicians participating in a MIPS APM). These MIPS-eligible clinicians do not need to submit a Quality Payment Program Exception Application.

For PY 2018, 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
  • Ambulatory Surgical Center (ASC)-based MIPS-eligible clinicians

A group’s Promoting Interoperability performance category score is reweighted automatically (or excepted, in the case of clinicians or groups participating in a MIPS APM). A group would not need to submit a Quality Payment Program Promoting Interoperability 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. The exception to this is a non-patient facing group.

Groups are considered non-patient facing if more than 75 percent of their clinicians have 100 or fewer patient facing encounters (including Medicare telehealth services). A non-patient facing group is automatically reweighted and does not need to submit a Quality Payment Program Exception Application.

If all 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. The group will have to report on the Promoting Interoperability performance category.

Extreme And Uncontrollable Circumstances Exception Overview

For PY 2018, MIPS-eligible clinicians who are impacted by extreme and uncontrollable circumstances may submit a request for reweighting of the Quality, Cost, and Improvement Activities performance categories.

"Extreme and uncontrollable circumstances" are defined as rare events (highly unlikely to occur in a given year) entirely outside your control and the facility in which you practice.

These extreme and uncontrollable circumstances would cause you to be unable to collect information necessary to submit for a performance category, or to submit information that would be used to score a performance category for an extended period of time (for example, 3 months unable to collect data for the Quality performance category).

How Do I Apply?

The Quality Payment Program Exception Application for PY 2018 is open from August 6, 2018 - December 31, 2018. You 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.

Apply for an Exception

To submit your application, you’ll need:

  • Your Taxpayer Identification Number (TIN) or National Provider Identifier (NPI)
    • 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
  • For Hardship Exception Applications, select the hardship exception category and supplemental information:
    • MIPS-eligible clinicians in small practices
    • MIPS-eligible clinicians using decertified EHR technology
    • Insufficient Internet connectivity
    • Extreme and uncontrollable circumstances
    • Lack of control over the availability of CEHRT
  • If you are applying for an Extreme and Uncontrollable Circumstance exception, you must provide a start and end date of when the circumstance (i.e. a natural disaster in which the CEHRT was damaged or destroyed) occurred.

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.

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