A Hurricane Ate my MIPS Homework – You Have Until December 31 to Apply for an Extreme Circumstance Exemption

The 2018 Quality Payment Program Exception Application period ends on December 31, 2018

If you are a practitioner who is subject to the Merit Based Incentive Payment System (MIPS), for the 2018 reporting year, there are two types of exceptions for which you might be eligible. If you are not sure whether you are subject to MIPS in the first place, you are not paying close enough attention to what’s going on, but at least you are reading this, so good for you! Start by finding out if you are subject to MIPS by checking your status at this link.

MIPS has 4 components:

  • Quality Reporting (the program that used to be called PQRS)
  • Cost (CMS calculates this for you)
  • Practice Improvement Activities (IA)
  • Promoting Interoperability (PI) (Meaningful Use of your EHR under another name hoping that we won’t hate it as much)

In 2018, there are two kinds of exceptions available. One of them gets you out of Promoting Interoperability (the Promoting Interoperability Hardship Exception) and the other could get you out of any of the categories (the Extreme and Uncontrollable Circumstances Exception).

The Extreme and Uncontrollable Circumstances Exception

The Extreme and Uncontrollable Circumstances Exception I call the Natural Disaster Exemption. “Extreme and uncontrollable circumstances” are defined as rare events (highly unlikely to occur in a given year) entirely outside your control and the facility in which you practice. These extreme and uncontrollable circumstances would cause you to be unable to collect information necessary to submit for a performance category, or to submit information that would be used to score a performance category for an extended period of time (for example, 3 months unable to collect data for the Quality performance category). As someone who practices in Houston, which got 52 inches of rain in Hurricane Harvey, I understand the challenges. Many practices, hospitals and wound centers were destroyed from Florida to Puerto Rico in several devastating storms. You have until December 31 to apply for The Extreme and Uncontrollable Circumstances Exception. In a future blog I will talk about an offer the USWR will make to wound care practitioners who are exempted from MIPS. 

The Promoting Interoperability Hardship Exception

Some MIPS-eligible clinicians and groups may qualify for a “re-weighting” of their Promoting Interoperability performance category score to 0%. In other words, the 25% that is contributed by PI is added to the Quality category so that Quality becomes worth 75% of the MIPS score in 2108. BUT- and this is important – Physicians working in the Hospital-based outpatient department don’t need to apply for this exception because they already have it! If you are a MIPS-eligible practitioner working in an on-campus HOPD, you are already exempt from submitting data in the PI category because you are considered a “Special Status” clinician. Also, if you are a Nurse Practitioner or Physician assistant, you are already exempt from submitting data on the PI category.

This is just to remind you that if you are a MIPS-eligible clinician or group, you have until December 31st to submit a Quality Payment Program Exception Application citing reasons such as: insufficient Internet connectivity, extreme and uncontrollable circumstances, or lack of control over the availability of certified health record technology.

Here’s the link:

https://qpp.cms.gov/mips/exception-applications

You may also contact the Quality Payment Program Service Center and work with a representative to verbally submit an application. Applications are subject to annual renewal.

To submit your application, you’ll need:

  • Your Taxpayer Identification Number (TIN) or National Provider Identifier (NPI)
  • NPI for individual applications
  • Group TIN for group applications
  • Contact information from person working on behalf of the individual clinician or group:
    • Submitter first name
    • Submitter last name
    • Submitter email address (This is how we will communicate with you.)
    • Submitter business telephone number (Include area code)
    • Submitter extension
  • For Hardship Exception Applications, select the hardship exception category and supplemental information:
    • MIPS-eligible clinicians in small practices
    • MIPS-eligible clinicians using decertified EHR technology
    • Insufficient Internet connectivity
    • Extreme and uncontrollable circumstances
    • Lack of control over the availability of CEHRT
  • If you are applying for an Extreme and Uncontrollable Circumstance exception, you must provide a start and end date of when the circumstance (i.e. a natural disaster in which the CEHRT was damaged or destroyed) occurred.

Once the application is submitted, you will receive a confirmation email that your application was submitted and is in a pending, approved, or dismissed status. Applications will be processed on a rolling basis.