Certified electronic health record technology (CEHRT) is required for participation in the advancing care information performance category of the Quality Payment Program (QPP). Under Merit-based Incentive Payment System (MIPS) scoring, MIPS-eligible clinicians and groups may qualify for a reweighting of their advancing care information performance category score to 0 percent of the final score if they meet the criteria outlined below. The 25 percent weighting of the advancing care information performance category would be reallocated to the quality performance category. Simply lacking CEHRT does not qualify the MIPS-eligible clinician or group for reweighting. MIPS-eligible clinicians and groups that are participating in a MIPS Alternative Payment Model may be exempted from reporting information for the advancing care information performance category if they meet the criteria outlined below:
A MIPS-eligible clinician or group may submit a Quality Payment Program Hardship Exception Application, citing one of the following specified reasons for review and approval:
Insufficient Internet Connectivity
Extreme and Uncontrollable Circumstances
Lack of Control over the availability of CEHRT
Special Status Clinicians
There are some MIPS-eligible clinicians that are considered Special Status, who will be automatically reweighted (or exempted in the case of MIPS-eligible clinicians participating in a MIPS APM) and do not need to submit a Quality Payment Program Hardship Exception Application.
For 2017, Special Status clinicians include the following:
Hospital-based MIPS-eligible clinicians
Physician Assistants
Nurse practitioners
Clinical nurse specialists
Certified registered nurse anesthetists
Non-patient facing clinicians
PROPOSED in Quality Payment Program Year 2 (82 FR 30077): Ambulatory Surgical Center (ASC) Based MIPS-Eligible Clinicians
The Quality Payment Program Hardship Exception Application for the 2017 transition year will open on August 2, 2017. Clinicians may also contact the Quality Payment Program Service Center and work with a representative to verbally submit an application. Or submit online at https://cmsqualitysupport.service-now.com/exception_application.do. Applications are subject to annual renewal.
To streamline the process, the application is available to both individual clinicians and groups. 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.