MIPS Exception

MIPS Exception

Index

  • Sections
    • MIPS Exception 2021
    • There are two exception applications available to clinicians in PY2021
  • Extreme and Uncontrollable Circumstances Exception
    • COVID-19
    • Can I Apply for an Extreme and Uncontrollable Circumstances Exception?

MIPS Exception 2021

How to check MIPs participation status:

Go to this website and enter your 10-digit National Provider Identifier (NPI) number to view your QPP participation status by performance year (PY). 

The website: https://qpp.cms.gov/participation-lookup 

Screenshot for MIPS Exception

Hardship Exceptions

You may submit a MIPS Promoting Interoperability Performance Category Hardship Exception Application, citing one of the following reasons for review and approval:

  • MIPS eligible clinician in a small practice
  • MIPS eligible clinician using decertified EHR technology
  • Insufficient Internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of CEHRT

If your hardship exception is approved, the Promoting Interoperability performance category will receive a weight of 0% when calculating your final score and the 25% will be redistributed to another performance category (or categories) unless you submit data for this performance category.

Some clinicians will be automatically reweighted based on special status (for example, hospital-based clinicians) or their clinician type (for example, a physical therapist, occupational therapist, or clinical psychologist). These clinicians will not need to submit a Promoting Interoperability Hardship Exception Application.

If you’re reporting as a group or virtual group all MIPS eligible clinicians in the group or virtual group must qualify for reweighting for the group to be reweighted, unless the group or virtual group has a special status that qualifies them for automatic reweighting.

There are two exception applications available to clinicians in PY2021

Extreme and Uncontrollable Circumstances Exception

MIPS eligible clinicians, groups, and virtual groups may submit an application to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances that impact these categories. Alternative Payment Model (APM) Entities may submit an application but are required to request reweighting for all performance categories.

COVID-19

The COVID-19 pandemic has impacted all clinicians across the United States and territories. However, we recognize that not all practices have been impacted by COVID-19 to the same extent. For PY 2021 we continue to use our extreme and uncontrollable circumstances policy to allow clinicians, groups, virtual groups, and APM Entities to submit an application requesting reweighting of performance categories due to the current COVID-19 public health emergency.

Can I Apply for an Extreme and Uncontrollable Circumstances Exception?

Yes. If you believe you have been affected by an extreme and uncontrollable circumstance (such as the public health emergency triggered by the COVID-19 pandemic), you can apply for this exception whether reporting traditional MIPS or the APM Performance Pathway (APP).

Extreme and uncontrollable circumstances are defined as rare events entirely outside of your control and the control of the facility in which you practice.

These circumstances would:

  1. Cause you to be unable to collect information necessary to submit for a MIPS performance category;
  2. 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 3 months), and/or;
  3. Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.
How Do I Apply?

You need a HCQIS Access Roles and Profile (HARP) account to submit an Extreme and Uncontrollable Circumstances Application. Once you sign into QPP with your HARP credentials, click ‘Exceptions Application’ on the left-hand navigation and then select ‘Extreme and Uncontrollable Circumstances.’

For more information on how to obtain a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide.

The Extreme and Uncontrollable Circumstances Exception Application deadline for PY 2021 is December 31, 2021 at 8 p.m. ET.

How Do I Know If I’m Approved?

You’ll be notified by email if your request was approved or denied. You can also check the status of your application by signing into QPP. If approved, this will also be added to your eligibility profile in the QPP Participation Status Tool on a rolling basis. If your application is approved at the end of the performance year, it may not appear in the lookup tool until the submission window is open in 2022.

What Happens If My Application is Approved?

If your application is approved, you don’t have to report for the requested MIPS performance category or categories, and those categories will be reweighted.

 
Reference:

CMS. (n.d.). About exception applications - QPP. Quality Payment Program. Retrieved September 20, 2021, from https://qpp.cms.gov/mips/exception-applications

 
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