All about the MIPS 2019 Hardship Exception Rules

CMS expects eligible clinicians to perform well in MIPS QPP. Sometimes despite the efforts, physicians are unable to meet even the minimum performance threshold.

We can’t blame them if they happen to suffer from unexpected hardships such as severe weather conditions or other unfavorable situations. CMS offers relaxation for such cases.

The time for sending applications for MIPS 2019 exceptions has started. Eligible clinicians, groups, and virtual groups now can apply in the exception context in two categories.

Promoting Interoperability (PI) Hardship Exception
Extreme and Uncontrollable Circumstances Exception

Exceptions will be offered only to those, who fulfill the criteria as specified by the CMS. Also, clinicians or groups who fall in the category of automatic reweighting of PI reporting shouldn’t have to apply for an exception.

MIPS 2019 Promoting Interoperability (PI) Hardship Exception

To submit for MIPS 2019 Promoting Interoperability (PI) measure, physicians must have access to the 2015 Certified Electronic Health Record Technology (CEHRT).

The net weight of the PI category is 25% of the total MIPS score. Clinicians unable to report in this measure will have their percentage shifted to the MIPS Quality measure category.

Who Can Apply for PI Exception?

The mere absence of the 2015 CEHRT will not grant any relaxation for PI data submission.

However, if you suffer from any of the below-mentioned scenarios, you qualify for the PI hardship exception criteria.

Inadequate/Unsatisfactory Internet connectivity
No Control over the access of CEHRT
Extreme and Controllable Circumstances
De-certified EHR technology
A small medical practice with fifteen or lesser clinicians with the same Tax identification number

There are special cases in which eligible physicians are already exempt from the PI category, and are not required to submit hardship exception applications of any sort.

For MIPS 2019, Clinicians with special cases are:

Non-Patient Facing clinicians
Hospital-based MIPS-eligible clinicians
MIPS-eligible clinicians associated with the Ambulatory Surgical Center (ASC)
Nurse practitioners, physician assistants, certified registered nurse anesthetists, clinical nurse specialists
Physical therapists, registered dietitians, occupational therapists, speech-language pathologists, clinical psychologists, audiologists, and nutrition professionals

Note: If you participate in MIPS 2019 as a group, all members should apply for a hardship exception to reweight the PI score for the group.

Extreme and Uncontrollable Circumstances Exception

CMS states that extreme and uncontrollable conditions refer to cases in which you have no control over anything or the facility in which you work.

By coming across such situations,

Clinicians may be unable to collect data for the PI category
Clinicians may be unable to submit data to CMS for a long time (For any performance category)

In case of such circumstances, eligible medical practitioners as either individuals or groups can apply for an exception in all of the four categories.

Quality
Cost
Improvement Activities (IA)
Promoting Interoperability (PI)

Upon requesting an exception, clinicians must report the category, which was affected by the extreme conditions along with the impact.

Required Information

Eligible clinicians and groups must have the following information:

For Virtual Group: VG ID
For Group: Group name & TIN (Tax Identification Number)
For Individual clinicians: Clinician’s NPI (National Provider Identifier), Group Name, Group TIN

How to Send Application?

Clinicians and groups can send their applications via the official QPP website. The applications must be sent out before December 31, 2019.

Either CMS approves or disapproves of your request for an exception; CMS will notify you. The approval status will also be updated on the physician’s profile (QPP Participation Status Tool).

There’s only a little time left to submit an application for MIPS 2019 hardship exception. Although, CMS doesn’t require supporting data for the application. But, it is advisable to retain any important information in case CMS asks for it (for validation or audit).

Learn about 3 Points to Consider Before MIPS 2019 Reporting!