The 2019 Quality Payment Program (QPP) Exception Applications for the Promoting Interoperability (PI) performance category and Extreme and Uncontrollable Circumstances for the Merit-based Incentive Payment System (MIPS) are now available on the QPP website.
Promoting Interoperability Hardship Exceptions
If you are participating in MIPS during the 2019 performance year as an individual, group, or virtual group – or participating in a MIPS Alternative Payment Model (APM) – you can submit a QPP Hardship Exception Application for the PI performance category, citing one of the following specified reasons for review and approval:
- You’re a small practice
- You have de-certified EHR technology
- You have insufficient internet connectivity
- You face extreme and uncontrollable circumstances
- You lack control over the availability of certified electronic health record technology (CEHRT)
An approved QPP Hardship Exception will:
- Reweight your PI performance category score to 0 percent of the final score
- Reallocate the 25 percent weighting of the PI performance category to the Quality performance category
Please note that simply not using CEHRT does not qualify you for reweighting of your PI performance category. If you’re already exempt from PI reporting, you do not need to apply for this exception.
You must submit a hardship exception application by December 31, 2019 for CMS to reweight the PI performance category to 0 percent. You will be notified by email if your request was approved or denied. Approval will be added to your eligibility profile in the QPP Participation Status Tool.
Note, MIPS eligible clinicians and Taxpayer Identification Numbers (TINs) participating in a MIPS APM do not need to report data for the PI performance category if they qualify for automatic reweighting or have an approved hardship exception. However, these clinicians will receive the APM entity score for Promoting Interoperability as determined by the APM scoring standard if the performance category is not reweighted for the entire entity.
Extreme and Uncontrollable Circumstances
MIPS eligible clinicians who are impacted by extreme and uncontrollable circumstances may submit a request for reweighting the Quality, Cost, and Improvement Activities performance categories.
“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 extreme and uncontrollable circumstances would cause you to either be:
- Unable to collect information necessary to submit for a performance category, OR
- Unable submit information that would be used to score a performance category for an extended period (for example, if you were unable to collect data for the Quality performance category for 3 months).
The automatic extreme and uncontrollable circumstances policy applies to MIPS eligible clinicians located in a CMS-designated region that’s been affected by an extreme and uncontrollable event, such as a FEMA-related major disaster, during the 2019 MIPS performance period. Affected MIPS eligible clinicians will have all four performance categories reweighted to 0 percent of their final scores unless they submit data for two or more performance categories.
The application for extreme and uncontrollable circumstances must be submitted by December 31, 2019 for the 2019 MIPS performance year. You will be notified by email if your request was approved or denied. Approval will be added to your eligibility profile in the QPP Participation Status Tool.
Questions? Contact your local technical assistance organization or the Quality Payment Program at QPP@cms.hhs.gov or 1-866-288-8292 (TTY: 1-877-715-6222).