Overall Hardship Exceptions

The COVID-19 pandemic has impacted clinicians across the United States and territories in many ways. For the 2020 performance year, the Centers for Medicare & Medicaid Services (CMS) is using its Extreme and Uncontrollable Circumstances policy to allow MIPS-eligible clinicians, groups, and virtual groups to submit an application requesting re-weighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency. The deadline has been extended, and applications are due to CMS by February 1, 2020.

MIPS Promoting Interoperability Hardship Exceptions

The deadline for the MIPS Promoting Interoperability Hardship Exception application will remain December 31, 2020. MIPS-eligible clinicians, groups, and virtual groups may qualify for a re-weighting of the Promoting Interoperability performance category to 0% if they:

• Are a small practice
• Have decertified EHR technology
• Have insufficient internet connectivity
• Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues
• Lack control over the availability of CEHRT

Learn more in the 2020 Exceptions Applications Fact Sheet. If you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply.

CMS has also proposed to allow APM Entities to submit an application to re-weight performance categories as a result of extreme and uncontrollable circumstances, such as the public health emergency resulting from the COVID-19 pandemic. Learn more in the 2021 Quality Payment Program Proposed Rule Overview Fact Sheet.

Applying

New for 2020: You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself or another MIPS-eligible clinician, group, virtual group, or APM Entity.

Once you register for a HARP account, sign in to qpp.cms.gov, click on the MIPS drop-down, and select ‘Exceptions Applications’ in the right-hand column.

If you apply for either of the exceptions, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but may not appear in the tool until the submission window is open in 2021.

If you have questions, contact the Quality Payment Program at 1.866.288.8292 or by email at: QPP@cms.hhs.gov.

Quanum Electronic Health Record (EHR) by Quest Diagnostics is fully certified to meet CMS regulatory requirements and is prepared to support your practice. Learn more by calling 1.888.835.3409 or email SalesSupport@Quanum.com.