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Reminder: QPP Promoting Interoperability and Extreme and Uncontrollable Circumstances Hardship Applications are Due December 31, 2019

The 2019 Quality Payment Program (QPP) Exemption Applications for the Promoting Interoperability (PI) performance category and Extreme and Uncontrollable Circumstances for the Merit-Based Incentive Payment System (MIPS) are available on the QPP website. Both applications are due by December 31, 2019.

Promoting Interoperability Hardship Exemption

Hardship exemptions for the Promoting Interoperability (PI) category of MIPS are available for physicians in groups of 15 or fewer Medicare-eligible clinicians or if they have experienced unforeseen and uncontrollable circumstances that prevent them from participating in the category, such as the vendor's loss of EHR certification.

Clinicians and groups who receive the hardship exemption will have the 25% weight of the category reassigned to the Quality category.

If you are going to apply for the small practice hardship, be sure to scroll down near the end and select option 2.5: “Small Practice.”

Click here to apply for the PI hardship exemption.

Extreme and Uncontrollable Circumstances Exemption

MIPS-eligible clinicians, groups, and virtual groups may submit an application for re-weighting of any or all MIPS performance categories if they've been impacted by extreme and uncontrollable circumstances that extend beyond the Promoting Interoperability performance category. Extreme and uncontrollable circumstances are defined as rare events entirely outside of your control, such as a natural disaster.

Click here to apply for the extreme and uncontrollable circumstances hardship exemption.

Additionally, CMS has determined that the automatic extreme and uncontrollable circumstances exemption will apply to MIPS eligible clinicians impacted by Hurricane Dorian in FEMA-identified North Carolina and South Carolina areas. Please note, the exemption will not apply to MIPS eligible clinicians in MIPS Alternative Payment Models (APMs) who are subject to the APM scoring standard for the 2019 performance period, or to those participating in MIPS as groups or virtual groups.

If you have any additional questions, please contact Allison Madson, manager of regulatory affairs, at or 703-591-2220.


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