Appendix H 2022 MIPS Promoting Interoperability Hardship Exception

 

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.Register for a HARP account  2.Sign in to qpp.cms.gov   3.Select ‘Exceptions Application’ on the left-hand navigation  4.Select ‘Add New Exception’   5.Select ‘Promoting Interoperability Hardship Exception’  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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