For CMS to reweigh one or more of these quality payment program performance categories, a clinician must, in the application, show that the clinician has encountered an uncontrollable circumstance or public health emergency, such as COVID-19, that is outside the provider’s control.
What are the MIPS Quality Payment Program Exceptions for Program Year 2020?
There are three exceptions for MIPS Quality Payment Program Year 2020.
MIPS Quality Payment Program Exceptions: #1 The MIPS Promoting Interoperability Performance Category Hardship Exception
The first of the three MIPS Quality Payment Program exceptions is the “MIPS Promoting Interoperability Performance Category Hardship Exception.” Under this exception, providers can submit an application that requests reweighing specifically for the “Promoting Interoperability” performance category. This category is one of the four scorable categories mentioned above.
This category requires completion of a security risk analysis. Some providers mistakenly believe that, if they receive a Promoting Interoperability Performance Category Hardship exception, they need not conduct a security risk analysis, period. This is untrue. HIPAA requires ALL providers to conduct a security risk analysis, regardless of whether the provider deals with CMS. CMS providers are simply eligible for incentives under MIPS if they do so.
MIPS eligible clinicians, groups, and virtual groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception Application citing one of the following specified reasons:
- You are 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 certified electronic health record technology (CEHRT).
Lacking CEHRT does not qualify you for re-weighting.