We understand that there may be circumstances out of your control that make it difficult for you to meet program requirements. To reduce this burden, we provide the opportunity to apply for exceptions to meeting Merit-based Incentive Payment System (MIPS) program requirements. In certain circumstances, these exceptions may be applied automatically. QPP exception guidelines may change each due to policy changes.
Performance Year
Select your performance year.
There are two exception applications available to clinicians in PY2022:
The MIPS Extreme and Uncontrollable Circumstances (EUC) exception application allows you to request reweighting for any or all performance categories if you encounter an extreme and uncontrollable circumstance or public health emergency (PHE), such as COVID-19, that is outside of your control.
- The MIPS Promoting Interoperability Performance category hardship Exception application allows you to request reweighting specifically for the Promoting Interoperability performance category if you qualify for one of the reasons identified below.
Extreme and Uncontrollable Circumstances Exception
MIPS eligible clinicians, groups, and virtual groups may submit an application to reweight any or all MIPS performance categories if they've been affected by extreme and uncontrollable circumstances that impact these performance categories. Alternative Payment Model (APM) Entities may submit an application but are required to request reweighting for all performance categories.
COVID-19
The COVID-19 PHE has impacted all clinicians across the United States and territories. However, we recognize that not all practices have been impacted by COVID-19 to the same extent. For PY 2022, we continue to use our MIPS EUC policy to allow clinicians, groups, virtual groups, and APM Entities to submit an application requesting reweighting of MIPS performance categories due to the current COVID-19 PHE.
We’ve extended the 2022 MIPS EUC Exception application to allow individuals, groups, virtual groups, and APM Entities to submit an application requesting MIPS performance category reweighting due to the ongoing COVID-19 PHE. 2022 MIPS EUC Exception applications citing COVID-19 as the triggering event can be submitted until 8 p.m. ET on Friday, March 3, 2023.
Learn more about all of the COVID-19 flexibilities we’ve implemented.
Can I Apply for an Extreme and Uncontrollable Circumstances Exception?
Yes. If you believe you have been affected by an extreme and uncontrollable circumstance (such as the PHE triggered by the COVID-19 pandemic), you can apply for this exception whether reporting traditional MIPS or the APM Performance Pathway (APP).
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 would:
- 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 processes, affecting your performance on cost measures and other administrative claims measures.
Is There an Instance When the Extreme and Uncontrollable Circumstances Exception is Automatically Applied?
Yes. MIPS eligible clinicians who are located in a Centers for Medicare & Medicaid Services (CMS) designated region that has been affected by an extreme and uncontrollable event (such as FEMA-designated major disaster) during PY 2022 receive the automatic extreme and uncontrollable circumstances exception. We identify qualifying events through the QPP Listserv. Subscribe at the bottom of any page on the website.
The automatic extreme and uncontrollable circumstances policy does not apply to group or virtual group participation.
MIPS eligible clinicians identified as affected by the automatic extreme and uncontrollable event will have all 4 MIPS performance categories reweighted to 0% of their final score, unless they submit data for 2 or more performance categories. These clinicians are automatically identified and don’t need to submit an exception application.
If you qualify for the automatic exception and have an approved exception application, the performance category reweighting from the automatic exception will supersede any performance category reweighting approved through the application.
How Do I Apply?
You need a HCQIS Access Roles and Profile (HARP) account to submit a MIPS EUC Exception application. Once you sign into QPP with your HARP credentials, click ‘Exceptions Application’ on the left-hand navigation and then select ‘Extreme and Uncontrollable Circumstances.’
For more information on how to obtain a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide.
The MIPS EUC Exception application deadline for PY 2022 has been extended to
8 p.m. ET on March 3, 2023. This extension is specific to applications submitted because of the ongoing COVID-19 PHE.
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 QPP. If approved, this 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 application period, you may not see this reflected in your eligibility profile until early 2023, soon after the submission window opens.
What Happens If My Application is Approved?
If your application is approved, you don’t have to report for the requested MIPS performance category or categories, and those categories will be reweighted.
Can I Still Submit Data?
Yes. Whether you qualify for automatic reweighting or have an approved exception application, you can still report data. If you submit data for 2 or more MIPS performance categories, you’ll receive a final score based on your performance in these categories.
What about APM Entities?
APM Entities participating in MIPS APMs can submit a MIPS EUC Exception application with some differences from our existing policy for individuals, groups, and virtual groups:
- APM Entities are required to request reweighting for all performance categories
- At least 75% of the MIPS eligible clinicians in the APM Entity will need to qualify for reweighting in the Promoting Interoperability performance category
- Data submission for an APM Entity won't override performance category reweighting
You will be notified by email if your request was approved or denied. You can also check the status of your application by signing into QPP. If approved, this approval 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 application period, you may not see this reflected in your eligibility profile until early 2023, soon after the submission window opens.
MIPS Promoting Interoperability Performance Category Hardship Exception
Beginning with the 2022 performance period, certified electronic health record technology (CEHRT) that meets the 2015 Edition certification criteria, 2015 Edition Cures Update certification criteria, or a combination of the two is required for participation in the Promoting Interoperability performance category. Under MIPS, you may qualify for reweighting of the Promoting Interoperability performance category (to 0%) if you meet certain criteria.
Can I Apply for a MIPS Promoting Interoperability Hardship Exception?
Yes. The MIPS Promoting Interoperability Performance Category Hardship Exception application period for PY 2022 is now available and applications can be submitted through 8 p.m. ET on January 3, 2023. MIPS eligible clinicians, groups, and virtual groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception application whether reporting traditional MIPS or the APM Performance Pathway (APP). This application isn’t available to APM Entities. Hardship exceptions are available for the following specified reasons:
- You have decertified 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 CEHRT
Simply lacking the required CEHRT doesn't qualify you for reweighting.
NOTE: If you're already exempt from submitting Promoting Interoperability data, you don't need to apply for this application. Learn more.
How Do I Apply?
You need a HCQIS Access Roles and Profile (HARP) account to submit a MIPS Promoting Interoperability Performance Category Hardship Exception application. Once you sign into QPP with your HARP credentials, select ‘Exceptions Application’ on the left-hand navigation and then select ‘Promoting Interoperability Hardship.’
For more information on how to obtain a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide.
You can submit a MIPS Promoting Interoperability Hardship Exception application for PY 2022 through 8 p.m. ET on January 3, 2023.
How Do I Know If I’m Approved?
You'll be notified by email if your request was approved or denied. You will also be able to check the status of your application by signing into QPP. If approved, this 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 application period, you may not see this reflected in your eligibility profile until early 2023, soon after the submission window opens.
What Happens If My Application is Approved?
If your application is approved, you don't have to report for the MIPS Promoting Interoperability performance category, and the category will be reweighted to 0% of your final score.
The 25% weighting of the Promoting Interoperability performance category will be redistributed to another performance category (or categories) unless you choose to submit data. If you submit data, the hardship will be cancelled and your data will be scored.
What If I'm a MIPS APM Participant?
MIPS eligible clinicians and groups with MIPS eligible clinicians participating in a MIPS APM can apply for hardship exceptions and qualify for automatic reweighting just like other MIPS eligible clinicians. If you’re participating in MIPS at the APM Entity level (either reporting traditional MIPS or the APP), you will receive the APM Entity’s score, but will be excluded from the calculation when we create an average Promoting Interoperability score for the APM Entity.
Can I Still Submit Data?
Yes. Whether you qualify for automatic reweighting or have an approved exception application, you can still choose to report. If you do submit data, we’ll score your performance and weight your Promoting Interoperability performance category at 25% of your MIPS final score. (Note: You will be scored in this performance category if you attest to any data during submissions, such as selecting performance period dates or answering measure questions.)