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Promoting Interoperability Hardship and Extreme and Uncontrollable Circumstances Exception Due
If you participate in the Merit-Based Incentive Payment System (MIPS) under the Center for Medicare & Medicaid Services (CMS) Quality Payment Program (QPP) and want to apply for a Promoting Interoperability Hardship Exception or an Extreme and Uncontrollable Circumstances Exception for the 2021 MIPS performance year, you must submit your application to CMS by 7 pm CT on Dec. 31, 2021. Eligible for a Promoting Interoperability Hardship Exception are MIPS-eligible clinicians, groups, and virtual groups that may qualify for a reweighting of the Promoting Interoperability performance category to 0% if they: -Are a small practice; -Have decertified electronic health record (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 certified EHR technology. Note: If you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply. Eligible for an Extreme and Uncontrollable Circumstances Exception are MIPS-eligible clinicians, groups, and virtual groups that may qualify for a reweighting 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 would: -Cause you to be unable to collect information necessary to submit for a MIPS performance category; -Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for three months), and/or; -Impact your normal processes, affecting your performance on cost measures and other administrative claims measures. 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 2021 MIPS performance year. These clinicians do not need to apply for the exception. Approval: 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 2022. Note: If you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply.
Centers for Medicare & Medicaid Services
12/31/2021
If you qualify and do not submit the exception application, then you will not have 25% of the Promoting Interoperability category reallocated to the Quality performance category, and the lack of points will count against your overall score. A lower score in the QPP results in an overall lower incentive payment or a penalty.
Be sure to apply for an exception if you think you qualify.
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