If you are a PrognoCIS user planning to submit the data for 2020 QPP MIPS and facing circumstances out of control that make it difficult to meet program requirements, CMS is providing the opportunity to submit the “exceptions application” to re-weight any or all MIPS performance categories.
There are two types of exception applications available; the application window for PY 2020 is currently open. Do not miss the deadline-December 31, 2020.
To apply for exceptions, you must set up a HCQIS Access Roles and Profile (HARP) account.
To learn about the complete exception application process you can access the QPP CMS Website
You’ll be notified by email as to whether your request was approved or denied.
Also, you can check the status of your application by signing into QPP.
The agency also will consider the extent to which those circumstances prevented clinicians from participating in MIPS and how long clinicians were subjected to those circumstances.
1. Extreme and Uncontrollable Circumstances Exception application allows clinicians to request reweighting for any or all performance categories if they encounter an extreme and uncontrollable circumstance or public health emergency, for example, COVID-19 pandemic, wildfire, a hurricane that is outside of their control.
MIPS eligible clinicians, groups, and virtual groups may submit an application to re-weight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances that impact these categories.
Automatic Extreme and Uncontrollable Circumstances Exception:
MIPS eligible clinicians who are located in a CMS-designated region that has been affected by an extreme and uncontrollable event (such as FEMA-designated major disaster), during the 2020 MIPS performance period, receive Automatic extreme and uncontrollable circumstances exception.
MIPS eligible clinicians identified as affected by an automatic extreme and uncontrollable event will have all four MIPS performance categories re-weighted to 0% of their final score unless they submit data for two or more performance categories.
The agency decided not to apply this policy to the COVID-19 pandemic. If the disaster area hasn’t yet been flagged as eligible for an automatic exemption, consider applying for extreme and uncontrollable circumstances reweighting before the deadline.
FEMA has designated new 2020 events, Hurricane Laura and the California and Oregon wildfires as national disasters.
MIPS eligible clinicians in these areas in 2020 will be automatically identified and receive a neutral payment adjustment for the 2022 MIPS payment year. During the data submission period for the 2020 performance year (January 4, 2021, to March 31, 2021), all 4 performance categories for these clinicians will be weighted at 0%, resulting in a score equal to the performance threshold.
However, if MIPS eligible clinicians in these areas choose to submit data on 2 or more performance categories, they will be scored on those categories and receive a 2022 MIPS payment adjustment based on their 2020 MIPS Final Score.
The automatic extreme and uncontrollable circumstances policy will not apply to:
- MIPS eligible clinicians in MIPS Alternative Payment Models (APMs)
- Participating in MIPS as groups or virtual groups.
2. MIPS Promoting Interoperability (PI) Performance Category Hardship Exception applications allow clinicians to request reweighting specifically for the Promoting Interoperability performance category if you qualify for one of the reasons identified.
If MIPS EC chooses to submit PI data, CMS will score performance and weight performance category at 25% of MIPS final score.
MIPS eligible clinicians, groups, and virtual groups may submit a MIPS PI Hardship Exception Application to reweight the PI performance category to 0 by citing one of the following specified reasons:
- small practice (15 or fewer clinicians);
- lack of control over the availability of CEHRT;
- decertified EHR technology;
- insufficient internet connectivity;
- extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues;
- Lacking CEHRT only does not qualify you for re-weighting.
Even if you qualify for automatic re-weighting or have an approved exception application, you can still choose to report.
CMS will score your performance and weight your Promoting Interoperability performance category at 25% of your MIPS final score.
For more information visit the QPP Resource / Webinar Library
- COVID-19 Fact Sheet
- 2020 Exception Applications Fact Sheet
- 2020 Automatic Extreme and Uncontrollable Circumstances Policy Fact Sheet
- 2020 Call for Promoting Interoperability Measures and Improvement Activities Webinar
- Overview of MIPS 2020 Performance Period Webinar
- 2020 Quality Payment Program Final Rule Webinar
QPP CMS Contacts : Phone : 1-866-288-8292 or ; e-mail at: QPP@cms.hhs.gov.
Please feel free to contact our PrognoCIS QPP/MU Support Team
Here’s how to contact us:
Log in to PrognoCIS – Go to Resource Centre – Click on the Manage Cases button and put a request for MIPS 2019 Submission/Attestation.