CMS Expects Eligible Clinicians to Perform Well in MIPS QPP
Challenges in Meeting Performance Thresholds
Despite their best efforts, some physicians may struggle to meet even the minimum performance threshold set by the Centers for Medicare & Medicaid Services (CMS). Such difficulties can arise from unforeseen challenges, including severe weather conditions and other adverse situations. In recognition of these hardships, CMS provides avenues for exceptions.
Application Period for MIPS 2019 Exceptions
The application period for MIPS 2019 exceptions has commenced. Eligible clinicians, groups, and virtual groups can apply under two specific categories:
1. Promoting Interoperability (PI) Hardship Exception
2. Extreme and Uncontrollable Circumstances Exception
To qualify for these exceptions, applicants must meet the criteria outlined by CMS. Notably, clinicians or groups eligible for automatic reweighting of PI reporting do not need to submit an exception request.
MIPS 2019 Promoting Interoperability (PI) Hardship Exception
Requirements for Submitting PI Measures
To submit measures for the MIPS 2019 Promoting Interoperability (PI) category, physicians must utilize 2015 Certified Electronic Health Record Technology (CEHRT). The PI category accounts for 25% of the total MIPS score. Clinicians who cannot report on this measure will have their percentage transferred to the MIPS Quality measure category.
Eligibility for PI Exception
The absence of 2015 CEHRT alone does not qualify for a PI data submission exemption. However, the following scenarios allow for a hardship exception:
– Inadequate or unsatisfactory internet connectivity
– Lack of control over access to CEHRT
– Extreme and controllable circumstances
– De-certified EHR technology
– Small practices with fifteen or fewer clinicians sharing the same Tax Identification Number (TIN)
Certain physicians are exempt from the PI category and do not need to apply for hardship exceptions, including:
– Non-patient facing clinicians
– Hospital-based MIPS-eligible clinicians
– MIPS-eligible clinicians affiliated with Ambulatory Surgical Centers (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
It is important to note that if participating in MIPS 2019 as a group, all members must apply for a hardship exception to modify the group’s PI score.
Extreme and Uncontrollable Circumstances Exception
Definition of Extreme and Uncontrollable Conditions
CMS defines extreme and uncontrollable circumstances as situations beyond the clinician’s control or outside the facility where they work. Under such conditions, clinicians may face challenges such as:
– Inability to collect data for the PI category
– Inability to submit data to CMS for an extended period across any performance category
Eligible medical practitioners, whether individuals or groups, can request an exception for all four performance categories:
1. Quality
2. Cost
3. Improvement Activities (IA)
4. Promoting Interoperability (PI)
When applying for an exception, clinicians must indicate the specific category affected by the extreme circumstances and detail the impact.
Required Information for Application
Eligible clinicians and groups must provide the following information in their applications:
– For Virtual Groups: VG ID
– For Groups: Group name and TIN (Tax Identification Number)
– For Individual Clinicians: Clinician’s NPI (National Provider Identifier), Group Name, Group TIN
Submission Process for Applications
Clinicians and groups can submit their applications through the official QPP website. All applications must be submitted before December 31, 2019. CMS will notify applicants of the approval or disapproval of their request, and the status will be updated on the physician’s profile via the QPP Participation Status Tool.
Final Considerations for MIPS 2019 Hardship Exception
The deadline to submit applications for the MIPS 2019 hardship exception is approaching. Although CMS does not require supporting documentation for the application, it is advisable to keep pertinent information on hand in case CMS requests it for validation or audit purposes.
Learn about three key points to consider before MIPS 2019 reporting!