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December 10, 2019

MIPS exception applications due Dec. 31

Medicare offers two opportunities for exception from certain requirements of the Merit-based Incentive Payment System (MIPS), but you must apply by Dec. 31.
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Promoting Interoperability Hardship Exception

If any of the following describes you or your practice, you have until Dec. 31, to apply for a Promoting Interoperability Hardship Exception for the 2019 Performance Year of MIPS. Certified electronic health record technology (CEHRT) is required for participation in the Promoting Interoperability performance category under MIPS. You may qualify for a re-weighting of the Promoting Interoperability performance category (to 0%) if you meet certain hardship criteria, but you must complete and submit the Promoting Interoperability Hardship Exception application by Dec. 31.

  • You’re a small practice.
  • You have decertified EHR technology.
  • You have insufficient internet connectivity.
  • You face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues.
  • You lack control over the availability of CEHRT.

Extreme and Uncontrollable Circumstances Exception

Has your practice been impacted by extreme and uncontrollable circumstances that extend beyond the Promoting Interoperability performance category? You may be eligible for an Extreme and Uncontrollable Circumstance Exception for the 2019 Performance Year of MIPS, but you must apply by Dec. 31.

If you are a MIPS eligible clinician located in a CMS-designated region that has been affected by an extreme and uncontrollable event (such as FEMA-designated major disaster) during the 2019 MIPS performance period, you will automatically be granted an exception; you do not need to apply. All four performance categories will automatically be re-weighted to 0% of your final score unless you submit data for two or more performance categories.

The automatic extreme and uncontrollable circumstances policy does not apply to group or virtual group participation.

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