Appendix H 2022 MIPS Promoting Interoperability Hardship Exception

Quality Payment Program (QPP)/Merit-Based Incentive Payment System (MIPS) (CMS-10621)

Appendix H 2022 MIPS Promoting Interoperability Hardship Exception Application Guide.pptx

CY 2024 Performance Period/2026 MIPS Payment Year Burden Summary

OMB: 0938-1314

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Contents

How to Use This Guide                                                                        3

MIPS Promoting Interoperability Performance Category Hardship Exception Application Overview                                                                5

MIPS Promoting Interoperability Performance Category Hardship Exception Information for Individuals, Groups, and Virtual Groups                             7

MIPS Promoting Interoperability Performance Category Hardship Exception: Frequently Asked Questions                                                         12                                                                        MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps                                                                  14

Help, Resources, Glossary, and Version History                                  30

Appendix                                                                  34

 

How to Use This Guide

 


How to Use This Guide

 

MIPS Promoting Interoperability Performance Category Hardship Exception Application Overview

 

MIPS Promoting Interoperability Performance Category Hardship Exception Application Overview

Overview

What

MIPS Promoting Interoperability Hardship Exception applications allow you to request that your MIPS Promoting Interoperability performance category be reweighted to 0%.

Who

Individual clinicians, groups, and virtual groups reporting via traditional MIPS or the APM Performance Pathway (APP)

  • Third Party Intermediaries can submit an application with permission from the clinician or practice.  

Some clinicians, groups and virtual groups automatically qualify for reweighting of the Promoting Interoperability performance category. If you qualify for automatic reweighting, you don’t need to apply for a MIPS Promoting Interoperability Hardship Exception.

  • See Appendix A for information about the clinicians, groups and virtual groups that automatically qualify for reweighting of this performance category. 

Why

You can submit an application to have your MIPS Promoting Interoperability performance category reweighted to 0% if:

  • You have insufficient Internet connectivity 

  • You have decertified EHR technology 

  • You lack control over the availability of CEHRT 

    • oLacking 2015 Edition CEHRT doesn’t qualify as a reason to submit an exception application 

  • You face extreme and uncontrollable circumstances such as a disaster, practice closure, severe financial distress or vendor issues 

    • oIf you experience an extreme and uncontrollable circumstance that impacts multiple performance categories, the Extreme and Uncontrollable Circumstances exception application may be more suitable for your given circumstance.  

When

Now through January 3, 2023, at 8 p.m. ET.

Where

Sign in to qpp.cms.gov with your HCQIS Access and Roles Profile (HARP) account.

  • For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide (ZIP). 

How

  1. 1.Register for a HARP account 

  2. 2.Sign in to qpp.cms.gov  

  3. 3.Select ‘Exceptions Application’ on the left-hand navigation 

  4. 4.Select ‘Add New Exception’  

  5. 5.Select ‘Promoting Interoperability Hardship Exception’ 

  6. 6.Complete the application for individual, group or virtual group participation  

 

MIPS Promoting Interoperability Performance Category Hardship Exception Information for Individuals, Groups, and Virtual Groups

 

MIPS Promoting Interoperability Performance Category Hardship Exception: Frequently Asked Questions

 

MIPS Promoting Interoperability Performance Category Hardship Exception: Frequently Asked Questions

Question

Answer

Where Can I Look for a Status Update on Our MIPS Promoting Interoperability Performance Category Hardship Exception Application?

You can monitor your application status in your QPP Account on qpp.cms.gov.

Can Additional Staff Members Access/Receive Notifications About the Status of the MIPS Promoting Interoperability Performance Category Hardship Exception Application?

Yes, you can add additional staff or representatives who should receive notifications about the status of the application.

In the Additional Access section of the application, provide the email address(es) of additional staff or representatives who would like to receive email notifications.

Please note: the additional staff or representatives must have HARP credentials in order to see the application on qpp.cms.gov

How Can I Correct a Mistake Made on Our MIPS Promoting Interoperability Performance Category Hardship Exception Application?

If you identified an error with your exception application, please contact the Quality Payment Program at 1-866-288-8292, Monday through Friday, 8 a.m.-8 p.m. ET or by e-mail at: QPP@cms.hhs.gov.

 

MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps

 

 

 

 

 

Participation Level

Required Information

Individual Clinician

  • National Provider Identifier (NPI) 

  • Practice Affiliation 

Group

  • Taxpayer Identification Number (TIN) 

Virtual Group

  • Virtual Group Identifier 

 

 

 

 

 

 

 

 

 

 

Help, Resources, Glossary, and Version History

 

Date

Description

10/06/2022

Updated deadline to request an exception to January 3, 2023, at 8 p.m. ET (slides 6 and 16)

05/02/2022

Original Posting.

 

Appendix

 

Reason for Reweighting (Individual Clinicians)

Action Needed by the Individual

You have one of these Special Statuses:

  • (New) Small Practice; 

  • Ambulatory Surgical Center (ASC)-based; 

  • Hospital-based; or 

  • Non-patient facing  

None – You are automatically excepted from having to submit data for this performance category as an individual, though you may still choose to do so.

You will be scored in this performance category if your practice is participating as a group or virtual group and doesn’t qualify for reweighting.

You are one of these clinician types:

None – You are automatically excepted from having to submit data for this performance category as an individual, though you may still choose to do so.

You will be scored in this performance category if your practice is participating as a group or virtual group and doesn’t qualify for reweighting.

Reason for Reweighting (Groups and Virtual Groups)

Action Needed by the Group or Virtual Group

You have one of these Special Statuses:

  • Ambulatory Surgical Center (ASC)-based. 

  • Hospital-based:  

    • oGroup or virtual group must have more than 75% of clinicians designated as hospital-based. 

  • Non-patient facing: 

    • oGroup or virtual group must have more than 75% of clinicians designated as non-patient facing. 

You will be scored in this performance category if your practice is participating as a group or virtual group and doesn’t qualify for reweighting.

 

All of the MIPS eligible clinicians in your group or virtual group qualify for reweighting as individuals (through any combination of special statuses, clinician type, and approved hardship exceptions).

You will be scored in this performance category if your practice is participating as a group or virtual group and doesn’t qualify for reweighting.

  • (New) Clinical social worker 

  • Physician assistant 

  • Nurse practitioner 

  • Clinical nurse specialist 

  • Certified registered nurse anesthetist 

  • Physical therapist 

  • Occupational therapist 

  • Qualified speech-language pathologist 

  • Qualified audiologist 

  • Clinical psychologist 

  • Registered dietitian or nutrition professional 

 

MIPS Performance Category Reweighting Scenario

Quality Category Weight

Cost Category Weight

Improvement Activities Category Weight

Promoting Interoperability Category Weight

No Reweighting

Standard Weighting under traditional MIPS

30%

30%

15%

25%

Reweight 1 Performance Category

No Cost

(Cost Quality and Promoting Interoperability)

55%

0%

15%

30%

No Improvement Activities

(Improvement Activities Quality)

45%

30%

0%

25%

No Promoting Interoperability

(Promoting Interoperability Quality)

55%

30%

15%

0%

No Quality

(Quality Promoting Interoperability)

0%

30%

15%

55%

 

MIPS Performance Category Reweighting Scenario

Quality Category Weight

Cost Category Weight

Improvement Activities Category Weight

Promoting Interoperability Category Weight

Reweight 2 Performance Categories

No Cost + No Promoting Interoperability

(Cost + Promoting Interoperability Quality)

85%

0%

15%

0%

No Cost + No Quality

(Cost + Quality Promoting Interoperability)

0%

0%

15%

85%

No Cost + No Improvement Activities

(Cost + Improvement Activities Promoting Interoperability + Quality)

70%

0%

0%

30%

No Promoting Interoperability + No Quality

(Promoting Interoperability + Quality Cost + Improvement Activities)

0%

50%

50%

0%

No Promoting Interoperability + No Improvement Activities

(Promoting Interoperability + Improvement Activities Quality)

70%

30%

0%

0%

No Quality + No Improvement Activities

(Quality + Improvement Activities Promoting Interoperability)

0%

30%

0%

70%

 

MIPS Performance Category Reweighting Scenario

Quality Category Weight

Cost Category Weight

Improvement Activities Category Weight

Promoting Interoperability Category Weight

Reweight 3 Performance Categories

If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you will receive a score equal to the performance threshold regardless of any data submitted or not and receive a neutral payment adjustment.

Reweight 4 Performance Categories

If all performance categories are reweighted to 0%, you will receive a score equal to the performance threshold regardless of any data submitted or not and receive a neutral payment adjustment.

 

MIPS Performance Category Reweighting Scenario under the APP

Quality Category Weight

Cost Category Weight

Improvement Activities Category Weight

Promoting Interoperability Category Weight

No Reweighting

Standard Weighting under the APP

50%

0%

20%

30%

Reweight 1 Performance Category

No Promoting Interoperability

(Promoting Interoperability Quality)

75%

0%

25%

0%

No Quality

(Quality Promoting Interoperability)

0%

0%

25%

75%

Reweight 2 + Performance Categories

If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you will receive a score equal to the performance threshold regardless of any data submitted or not and receive a neutral payment adjustment.

 

Draft in Progress

Submitted – Pending Approval

Approved / Denied

Withdrawn

    

You are currently working on your application and haven’t submitted it application yet.

Select Manage to continue working on your application.

You have successfully completed and submitted your application.

Applications are reviewed in the order of which they are received.

We completed our review of your application and approved your request.

You have withdrawn your application. You can withdraw your application at any point in the process.

An application can’t be re-opened after being withdrawn. You’ll need to complete a new application.

 

We completed our review of your application and denied your request.

 
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