Reminder: Applications for the 2020 Promoting Interoperability Hardship and Extreme and Uncontrollable Circumstances Exception are Due December 31

If you are interested in applying for a Merit-based Incentive Payment System (MIPS) Promoting Interoperability Hardship Exception or Extreme and Uncontrollable Circumstances Exception for the 2020 Performance Year of MIPS, you must submit your application to CMS by Thursday, December 31, 2020 at 8:00 p.m. ET.

Who is Eligible for a MIPS 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.
Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.

COVID-19 Flexibilities

The COVID-19 pandemic has impacted all clinicians across the United States and territories. However, CMS recognizes that not all practices have been impacted by COVID-19 to the same extent. For the 2020 performance year, CMS will be using our Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency. For more information, visit the QPP COVID-19 Response webpage.

Note: CMS is proposing to allow APM Entities to submit an application to reweight MIPS 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.

How do I Apply?

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 or virtual group. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you register for a HARP account, sign in to qpp.cms.gov, select ‘Exceptions Applications’ on the left-hand navigation, select ‘Add New Exception,’ and select ‘Extreme and Uncontrollable Circumstances Exception’ or ‘Promoting Interoperability Hardship 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 2021.

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.
Check out the Exceptions Application Fact Sheet to learn more about these exceptions.

Questions?

Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.

Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

Reminder: CMS Proposes to Allow APM Entities to Submit Applications for the Extreme and Uncontrollable Circumstances Exception; Applications are Due December 31

In the 2021 Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM), the Centers for Medicare & Medicaid Services (CMS) proposed to allow APM Entities to submit an application to reweight Merit-based Incentive Payment System (MIPS) performance categories as a result of extreme and uncontrollable circumstances. We intend to allow APM Entities to submit applications now, but CMS will not be able to make final determinations on applications until and unless the policy proposal is finalized.

If the policy is finalized and an APM Entity’s application is approved, that APM Entity would receive a final score equal to the performance threshold for the 2020 MIPS performance year, and the MIPS eligible clinicians in the APM Entity group would receive a neutral payment adjustment in 2022.

Who is Eligible to Submit an Application?

If the policy is finalized, then APM Entities affected by extreme and uncontrollable circumstances in the following models would be able to submit an application:

Medicare Shared Saving Program
Next Generation ACO Model
Vermont Medicare ACO Model
Comprehensive Primary Care Plus (CPC+)
Comprehensive ESRD Care (CEC)
Bundled Payments for Care Improvement (BPCI)
Oncology Care Model (OCM)
Maryland Primary Care Program
Independence at Home Demonstration

What are the Application Requirements?

Unlike those who choose to apply as individual clinicians, groups, or virtual groups, APM Entities must apply to reweight all MIPS performance categories to 0%. Additionally, 75% of the MIPS eligible clinicians in the APM Entity must qualify for reweighting in the MIPS Promoting Interoperability performance category. They may qualify automatically or through a MIPS Promoting Interoperability Hardship Exception Application.

CMS does not require APM Entities to submit documentation with their applications. However, APM Entities should retain documentation of the circumstances supporting their application for their own records in the event they are selected by CMS for data validation or an audit.

When are Applications Due?

Applications are due to CMS by Thursday, December 31, 2020 at 8:00 p.m. ET.

How do I Apply?

New for 2020: You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

How do I Know if I’m Approved?

If you submit an application and this policy is finalized to allow APM Entities to apply, then 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 it may not appear in the tool until the submission window is open in 2021.

Will Submitting Data Void the Exception?

Data submitted for an APM Entity will not override performance category reweighting from an approved application. This differs from the policy for individual, group, and virtual group applications.

Will an Approved Application Affect Model-Specific Reporting Requirements?

If the policy is finalized and an APM Entity’s application is approved, the approval would only affect MIPS reporting, and that APM Entity would still be required to meet its model-specific reporting requirements.

For More Information

Visit the Extreme and Uncontrollable Circumstances Exception QPP webpage for more information and links to each application.
Check out the Exceptions Application Fact Sheet to learn more about this exception.

Questions?