Are You Eligible for a MIPS Hardship Exception?

keyboard-computer-articleAre there circumstances that are making it difficult for you to meet the Quality Payment Program’s Merit-based Incentive Payment System (MIPS) requirements for the 2018 performance year (PY)? You may be eligible to apply for a hardship exception.

MIPS-eligible physicians and practices may apply for hardship exceptions for either the Promoting Interoperability MIPS performance category or for extreme and uncontrollable circumstances. The extreme and uncontrollable circumstances exception applies only to those who have experienced a rare event entirely outside of their control that would prevent MIPS participation for an extended time.

Exception applications are due by Dec. 31, 2018.

If you’re not sure whether you’re required to participate in the Quality Payment Program in 2018, you can find out using CMS’ Participation Status Tool.

A Closer Look at the Promoting Interoperability Hardship Exception

MIPS-eligible clinicians and groups can apply for a reweighting of their Advancing Care Information (ACI) performance category score to 0 percent of the final score.

Without the exception, the Promoting Interoperability category – previously called the Advancing Care Information category — will be weighted at 25 percent in PY 2018. If the Centers for Medicare and Medicaid services determines that you are eligible for an exception, the 25 percent weighting would be reallocated to the Quality performance category.

Hardship exception applications can be submitted for one of the following specified reasons:

MIPS eligible clinicians in small practices – Small practices experiencing significant hardship in adopting and implementing Certified EHR Technology (CEHRT) can apply for an exception.

  • MIPS-eligible clinicians using decertified EHR technology – You can apply if your performance period ended after the decertification occurred.
  • Insufficient internet connectivity – You may be eligible if your office is in an area with insufficient internet access.
  • Extreme and uncontrollable circumstances – This exception is for those impacted by an event such as those designated by the Federal Emergency Management Agency as a major disaster.
  • Lack of control over the availability of CEHRT

Applications can be submitted online via this hardship exception application form.

Clinicians may also contact the Quality Payment Program Service Center and work with a representative to apply verbally. Once an application is submitted, you will receive a confirmation email that your application was submitted and is pending, approved, or dismissed. Applications will be processed on a rolling basis.

Special Status Clinicians Do Not Need to Apply for Hardship Exceptions

Certain MIPS-eligible clinicians are considered by CMS to have a "special status” in which a clinician will automatically be reweighted without needing to apply for a hardship exception. In 2018, special status clinicians include:

  • Hospital-based MIPS-eligible clinicians
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Non-patient facing clinicians
  • Ambulatory Surgical Center (ASC)-based MIPS-eligible clinicians

MIPS-eligible clinicians participating in a MIPS Alternative Payment Model (APM) are also not required to submit an exception application.

Additional Resources

CMS' Quality Payment Program website at offers resources on hardship exceptions, including a hardship exception webpage and an exceptions fact sheet.

The Pennsylvania Medical Society (PAMED) also provides comprehensive Quality Payment Program and MIPS guidance at PAMED members can also get personalized assistance by contacting our Knowledge Center at (855) 726-3348 or

And, check out PAMED's Care Centered Collaborative at for additional tools, resources, and expertise—including a MIPS Reporting Solution available at a discount to PAMED members.

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