CMS has released two hardship exception applications for program year 2018 for payment year 2020 on the Quality Payment Program web page, including: the Promoting Interoperability (PI) Hardship Application, which includes the small practice hardship for practices of 15 or fewer Medicare-eligible clinicians and the MIPS Program Extreme and Uncontrollable Circumstances Application.
Promoting Interoperability Hardship Exceptions
If you’re participating in MIPS during the 2018 performance year as an individual, group, or virtual group—or participating in a MIPS Alternative Payment Model (APM)—you can submit a Quality Payment Program Hardship Exception Application for the PI performance category, citing one of the following specified reasons for review and approval:
- MIPS-eligible clinicians in small practices (new for 2018)
- MIPS-eligible clinicians using decertified EHR technology (new for 2018)
- Insufficient Internet connectivity
- Extreme and uncontrollable circumstances
- Lack of control over the availability of certified electronic health record technology (CEHRT)
An approved Quality Payment Program Hardship Exception will:
- Reweight your PI performance category score to 0 percent of the final score
- Reallocate the 25% weighting of the PI performance category to the Quality performance category
You must submit a hardship exception application by December 31, 2018, for CMS to reweight the PI performance category to 0%.
Extreme and Uncontrollable Circumstances
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). In your application, you must indicate the performance categories that were subject to an extreme and uncontrollable circumstance and how the circumstance affected your ability to collect or submit data for the 2018 MIPS performance year.
The application for extreme and uncontrollable circumstances must be submitted by December 31, 2018, for the 2018 MIPS performance year.
Please review the Hardship Exceptions FAQs for more information. As always, if you have additional questions, please call the MACRA Hotline at 703-383-5724, or contact Allison Madson, manager of regulatory affairs, at firstname.lastname@example.org