Claiming a Hardship Exception
CMS allows clinicians to file for a hardship exception to avoid negative payment adjustments under specific circumstances. If granted, the hardship exception applies only to one performance year and is not automatically renewable in subsequent years. At its discretion, CMS may broaden the hardship exception criteria from year to year to accommodate clinicians impacted by such extreme and uncontrollable circumstances as hurricanes, wildfires, and pandemics.
To learn more about the general hardship exception criteria, visit the Quality Payment Program website.
CMS recognizes that clinicians have been impacted by COVID-19 to varying degrees and is allowing clinicians to apply to be excluded from one or more or all MIPS performance categories. Clinicians or groups who are applying for a hardship exception should be prepared to describe how extreme and uncontrollable circumstances interfered with their ability to
- collect information necessary to submit for a MIPS performance category;
- submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the Quality performance category for 3 months); or
- perform your normal processes, affecting your performance on cost measures and other administrative claims measures.
If these circumstances apply to you, apply for a hardship exception prior to December 31, 2020, at 8:00 p.m. ET.
If your hardship exception application is approved, you do not have to report the excepted performance category or categories. The excepted categories will be reweighted to 0% of your MIPS score, and your MIPS score will be determined from any remaining performance categories. If your hardship exception is approved and you submit MIPS data anyway, you will receive a MIPS score, provided you submitted data for at least two performance categories. For more information, visit the Quality Payment Program website.
CMS is offering sweeping hardship exceptions for the Promoting interoperability performance category for clinicians working in small practices (15 or fewer clinicians) or in areas with insufficient internet connectivity. If you meet either of these criteria, apply for a Promoting Interoperability hardship exception prior to December 31, 2020, at 8:00 p.m. ET.
If your application is approved, you do not have to report for the MIPS Promoting Interoperability performance category, and the category will be reweighted to 0% of your MIPS score, and your MIPS score will be determined by the remaining performance categories. If your hardship exception is approved and you submit Promoting Interoperability data anyway, you will receive a Promoting Interoperability score. For more information, visit the Quality Payment Program website.