If you participate in the Merit-Based Incentive Payment System (MIPS) under the Centers for Medicare & Medicaid Services (CMS) Quality Payment Program (QPP) and want to apply for a Promoting Interoperability (PI) Hardship Exception or an Extreme and Uncontrollable Circumstances Exception for the 2020 MIPS performance year, you must submit your application to CMS by Feb. 1, 2021. The application deadline has been extended to Feb. 1, 2021. The previous deadline was Dec. 31, 2020.
Eligible for a PI Hardship Exception are MIPS-eligible clinicians, groups, and virtual groups who may qualify for a reweighting of the PI performance category to 0% if they are a small practice; have decertified electronic health record (EHR) technology; have insufficient internet connectivity; face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues; or lack control over the availability of certified EHR technology. Note: If you’re already exempt from reporting PI data, you don’t need to apply.
Eligible for an Extreme and Uncontrollable Circumstances Exception are MIPS-eligible clinicians, groups, and virtual groups who may qualify for a reweighting of any or all MIPS performance categories to 0% if they are affected by extreme and uncontrollable circumstances extending beyond the PI performance category. These circumstances must render them unable to collect information necessary to submit information for a performance category or submit information that would be used to score a performance category for an extended period. Note: Individual MIPS-eligible clinicians (not groups or virtual groups) will receive the exception automatically if they are located in a CMS-designated region that has been affected by an extreme and uncontrollable event during the 2020 MIPS performance year. These clinicians do not need to apply for the exception.
If you apply for either exception, you will be notified by email if your request was approved or denied. If approved, this will be added to your eligibility profile on the QPP Participation Status Tool but may not appear in the tool until the submission window is open in 2021.
If you qualify and do not submit the exception application, you will not have 25% of the PI performance category reallocated to the Quality performance category, and the lack of points will count against your overall score. A lower score in the QPP results in an overall lower incentive payment or a penalty.
If you are eligible, submit an exception application to CMS at https://qpp.cms.gov/mips/exception-applications by Feb. 1, 2021.