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QPP Exception Applications

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

performance year
due to policy changes.

Performance Year

Select your performance year.

There are 2 exception applications available to clinicians:

MIPS EUC 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. Clinicians that register to report a MIPS Value Pathway (MVP) as a subgroup will inherit any reweighting approved for their affiliated group; if the subgroup encounters an extreme and uncontrollable circumstance that doesn’t affect the entire group, the subgroup can contact the QPP Service Center to request reweighting. Alternative Payment Model (APM) Entities may submit an application but are required to request reweighting for all performance categories.

Updated

Can I Apply for a MIPS EUC Exception?

As announced through the QPP listserv on September 23, 2024, CMS is providing another opportunity to submit MIPS performance category reweighting requests for the 2023 performance year due to the Change Healthcare cyberattack in late February. Any clinician, group, subgroup, virtual group, or APM Entity that wasn’t able to submit their MIPS data because of the Change Healthcare cyberattack can request reweighting.

IMPORTANT: We’re allowing PY 2023 MIPS EUC reweighting requests under our MIPS EUC Exception policy to be submitted through the Targeted Review form until October 11, 2024, at 8 p.m. ET.

Due to technical limitations, we’re unable to reopen the PY 2023 MIPS EUC Exception Application form in our system.

Updated

How Do I Apply?

You need a Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) account to submit a PY 2023 MIPS EUC reweighting request through the Targeted Review form.

  • Sign in to QPP with your HARP credentials.
  • Click ‘Targeted Review’ on the left-hand navigation and fill in the necessary fields.
  • Select “Extreme and uncontrollable circumstances” as the Issue and include “Change Healthcare Cyberattack” when asked to provide specific details. 

For more information, refer to the Performance Year 2023 Merit-based Incentive Payment System Extreme and Uncontrollable Circumstances Reweighting Requests for Change Healthcare Cyberattack Extension Guide (PDF, 675KB).  

Can APM Entities Submit an Exception Application?

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

MIPS Promoting Interoperability Performance Category Hardship Exception

Certified electronic health record technology
(CEHRT) that meets the 2015 Edition Cures Update certification criteria is required for participation in the Promoting Interoperability performance category in the 2023 performance period. 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?

The MIPS Promoting Interoperability Performance Category Hardship Exception application for the 2023 performance period closed at 8 p.m. ET on January 2, 2024. MIPS eligible clinicians, groups, and virtual groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception application whether reporting traditional MIPS, MVPs, or the 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 a 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'll need a HCQIS Access Roles and Profile (HARP) account to submit a MIPS Promoting Interoperability Performance Category Hardship Exception application. Once you sign in to 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 (ZIP).  

The MIPS Promoting Interoperability Hardship Exception application period is now closed. The application deadline for 2023 was 8 p.m. ET on January 2, 2024.

How Do I Know If I’m Approved? 

You'll be notified by email if your request was approved or denied. You'll also be able to check the status of your application by signing in to 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 performance year, it may not appear in the QPP Participation Status Tool until the submission window is open in 2024.

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 Promoting Interoperability performance category weight 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, MVPs, or the APP), you'll 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 the Promoting Interoperability performance category will count towards your MIPS final score. (Note: You'll be scored in this performance category if you attest to any data during the submission period, such as selecting performance period dates or answering measure questions.)

When is the Promoting Interoperability Performance Category Automatically Reweighted?

There are several clinician types and special status designations that result in automatic reweighting. These clinicians, groups, virtual groups, and APM Entities are exempt from reporting Promoting Interoperability data for the 2023 performance year:

  • Clinician type: clinical social workers, physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, and registered dieticians or nutrition professionals
  • Special status: ambulatory surgical center (ASC)-based, hospital-based, non-patient-facing, and small practice 
    Note: small practice is the only special status available to APM Entities

If you’re reporting as a group or virtual group, all MIPS eligible clinicians in the group or virtual group must qualify for reweighting for the group to be reweighted, unless the group or virtual group has a special status that qualifies them for automatic reweighting.