Reminder: Applications for the 2019 Promoting Interoperability Hardship and Extreme and Uncontrollable Circumstances Exceptions are Due December 31

If you are interested in applying for a Promoting Interoperability Hardship Exception or Extreme and Uncontrollable Circumstances Exception for the 2019 Performance Year of MIPS, you must submit your application to CMS by Tuesday, December 31, 2019.

Who is Eligible for a Promoting Interoperability Hardship Exception?

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; or
Lack control over the availability of CEHRT

Note: If you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply.

Who is Eligible for an Extreme and Uncontrollable Circumstances Exception?

MIPS eligible clinicians, groups, and virtual groups may qualify for a re-weighting of any or all MIPS performance categories to 0% if they are affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must render them unable to:

Collect information necessary to submit for a performance category; or
Submit information that would be used to score a performance category for an extended period of time.

Note: Individual MIPS eligible clinicians (not groups or virtual groups) will receive the exception automatically if they are located in a CMS-designated region that has been affected by an extreme and uncontrollable event during the 2019 MIPS Performance Year. These clinicians will not need to apply for the exception.

How do I Know if I’m Approved?

If you submit an application 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 2020.

For More Information

Visit the Promoting Interoperability Hardship Exception and Extreme and Uncontrollable Circumstances Exception QPP webpages for more information and links to each application.
Download the 2019 Exceptions FAQs to learn more about these exceptions.
Check out the 2019 MIPS Automatic Extreme and Uncontrollable Circumstances Policy Fact Sheet to learn more about who automatically receives the exception.

Contact the Quality Payment Program at QPP@cms.hhs.gov or 1-866-288-8292 (TTY: 1-877-715-6222). To receive assistance more quickly, consider calling during non-peak hours—before 10 AM and after 2 PM ET.

Reminder: Virtual Groups Election Period for MIPS 2020 Performance Period Ends December 31

If you’re interested in forming a virtual group for the 2020 Merit-based Incentive Payment System (MIPS) performance year, you must follow the election process and submit your election to CMS via e-mail by Tuesday, December 31, 2019. Details about virtual groups and the election process are available in this toolkit.

What is a Virtual Group?

A virtual group is a combination of two or more Taxpayer Identification Numbers (TINs) assigned to:

One or more solo practitioners (who are MIPS eligible clinicians); or
One or more groups consisting of 10 or fewer clinicians (including at least 1 MIPS eligible clinician); or
Both (solo practitioners and groups of 10 or fewer clinicians) that elect to form a virtual group for a performance period for a year

What is the Election Process?

There is a two-stage election process for forming a virtual group:

Stage 1 (optional)

Contact your Quality Payment Program Technical Assistance organization for information regarding TIN size to help you determine if you meet the TIN size criteria to join or form a virtual group.

Stage 2 (required)

As part of Stage 2 of the election process, you must:

Have a formal written agreement.
Name an official virtual group representative.
Submit the virtual group’s election via e-mail to CMS at MIPS_VirtualGroups@cms.hhs.gov by Tuesday, December 31, 2019.
Determine group size and low-volume threshold.

Download the 2020 Virtual Groups Toolkit to learn more about the election process and how to participate in MIPS as a virtual group in 2020.

Need Help?

Contact the Quality Payment Program by:
- Email: QPP@cms.hhs.gov or
- Phone: 1-866-288-8292/ TTY: 1-877-715-6222; to receive assistance more quickly, consider calling during non-peak hours – from 8:00 am to 10:00 am, and 2:00 pm to 8:00 pm Eastern Standard Time (EST).
Clinicians in small practices (including those in rural locations), health professional shortage areas, and medically underserved areas may request technical assistance from on-the-ground organizations that can provide no-cost support. To learn more about this support, or to connect with your local technical assistance organization, we encourage you to visit our Small, Underserved, and Rural Practices page on the Quality Payment Program website.
Visit Help and Support for additional information and resources.