Small Practices Can Get a Pass on MIPS Promoting Interoperability in 2018
By David Doolittle


It’s none of my business, of course, but sometimes practices go through some rough patches and could use a little help — especially when it comes to complying with Medicare’s Merit-Based Incentive Payment System (MIPS).  

If your practice has 15 or fewer eligible clinicians and is experiencing some type of “significant hardship” that has created “overwhelming barriers” to complying with MIPS’ Promoting Interoperability (PI) category, you are eligible to submit a hardship application.

If you are eligible for a hardship exemption, the Centers for Medicare & Medicaid Services (CMS) will reweight the PI performance category to from 25 percent to zero percent when calculating your final score for the 2018 performance period. That 25 percent will then be reallocated to the quality performance category

Because CMS doesn’t thoroughly define what qualifies as a “significant hardship” or an “overwhelming barrier,” the Texas Medical Association recommends saving all documentation of your circumstances and how they’ve affected your ability to participate in the PI category. If you can’t back up the reasons for your hardship, your score may be adjusted back to pre-exemption status.   

The deadline to apply for a hardship exemption is Dec. 31, 2018. 

For additional information on Promoting Interoperability, view the TMA PI Resource Center. If you have questions related to MIPS or PI, call the TMA HIT helpline at (800) 880-5720, or e-mail hit[at]texmed[dot]org

Last Updated On

December 14, 2018

Originally Published On

October 24, 2018

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David Doolittle


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Dave Doolittle is editor of Texas Medicine and Texas Medicine Today. Dave grew up in Austin, where he attended culinary school as well as the University of Texas. He spent years covering Central Texas for the Austin American-Statesman newspaper. He is the father of two girls, a proud Longhorn, and an avid motorsports fan.

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