What You Should Know about MIPS Hardship Exceptions for the 2019 Performance Year

Last Updated: Sep 4, 2019

stethoscope_tablet_computerAre 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 2019 performance year? 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, 2019. Apply here

Important Note: Some clinicians may be exempt from the Promoting Interoperability category – hospital-based clinicians, for example – and will be automatically be reweighted based on their special status. Those clinicians do not need to submit a hardship exception application.

If you’re not sure whether you’re required to participate in the QPP this year or whether you are automatically exempt from Promoting Interoperability participation, you can find out using the Centers for Medicare and Medicaid Services’ (CMS) Participation Status Tool.

A Closer Look at the Promoting Interoperability Hardship Exception

If you are participating in MIPS during the 2019 performance year as an individual, group, or virtual group – or participating in a MIPS Alternative Payment Model (APM) – you can submit a Promoting Interoperability hardship exception application for one of the following reasons:

  • You are a small practice
  • You have decertified EHR Technology
  • You have insufficient internet connectivity
  • You face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
  • You lack control over CEHRT availability

Hardship exception applicants will be notified via email regarding whether your request is approved or denied.

If your application is approved, you do not have to report for the Promoting Interoperability performance category and the category will be re-weighted to 0 percent of your final score. The 25 percent weighting of the Promoting Interoperability performance category will be reallocated to the Quality performance category.

Additional Resources

CMS' Quality Payment Program website offers resources on hardship exceptions, including a QPP exceptions webpage here.

Pennsylvania Medical Society (PAMED) members with questions on participating in the QPP by contacting our Knowledge Center at (855) 726-3348 or KnowledgeCenter@pamedsoc.org.

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