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Update

We’re extending the MIPS Extreme and Uncontrollable Circumstances (EUC)
exception application deadline until March 3, 2023 for those that have been
affected by COVID-19. Any data submitted for an individual, group, or virtual
group will be scored. Data submission for an APM Entity won’t override
performance category reweighting from an approved application. Learn more.

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QPP Exception Applications page
 1. Home
 2. Reporting Factors Overview


QPP EXCEPTION APPLICATIONS

We understand that there may be circumstances out of your control that make it
difficult for you to meet program requirements. To reduce this burden, we
provide the opportunity to apply for exceptions to meeting Merit-based Incentive
Payment System (MIPS) program requirements. In certain circumstances, these
exceptions may be applied automatically. QPP exception guidelines may change
each performance year due to policy changes.


PERFORMANCE YEAR

Select your performance year.

Performance Year 2023Performance Year 2022Performance Year 2021Performance Year
2020Performance Year 2019Performance Year 2018Performance Year 2017

There are two exception applications available to clinicians in PY2022:

 * The MIPS Extreme and Uncontrollable Circumstances (EUC) exception application
   allows you to request reweighting for any or all performance categories if
   you encounter an extreme and uncontrollable circumstance or public health
   emergency (PHE), such as COVID-19, that is outside of your control.

 * The MIPS Promoting Interoperability Performance category hardship
   Exception application allows you to request reweighting specifically for the
   Promoting Interoperability performance category if you qualify for one of the
   reasons identified below.


EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION

MIPS eligible clinicians, groups, and virtual groups may submit an application
to reweight any or all MIPS performance categories if they've been affected by
extreme and uncontrollable circumstances that impact these performance
categories. Alternative Payment Model (APM) Entities may submit an application
but are required to request reweighting for all performance categories.


COVID-19

The COVID-19 PHE has impacted all clinicians across the United States and
territories. However, we recognize that not all practices have been impacted by
COVID-19 to the same extent. For PY 2022, we continue to use our MIPS EUC policy
to allow clinicians, groups, virtual groups, and APM Entities to submit an
application requesting reweighting of MIPS performance categories due to the
current COVID-19 PHE.

Updated

We’ve  extended the 2022 MIPS EUC Exception application to allow individuals,
groups, virtual groups, and APM Entities to submit an application requesting
MIPS performance category reweighting due to the ongoing COVID-19 PHE. 2022 MIPS
EUC Exception applications citing COVID-19 as the triggering event can be
submitted until 8 p.m. ET on Friday, March 3, 2023.

Learn more about all of the COVID-19 flexibilities we’ve implemented


PY 2022 EUC EXCEPTION APPLICATION IS AVAILABLE UNTIL 8 P.M. ET ON MARCH 3, 2023


Apply


CAN I APPLY FOR AN EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION?

Yes. If you believe you have been affected by an extreme and uncontrollable
circumstance (such as the PHE triggered by the COVID-19 pandemic), you can apply
for this exception whether reporting traditional MIPS or the APM Performance
Pathway (APP).

Extreme and uncontrollable circumstances are defined as rare events entirely
outside of your control and the control of the facility in which you practice.

These circumstances would:

 * Cause you to be unable to collect information necessary to submit for a MIPS
   performance category;
 * Cause you to be unable to 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), and/or;
 * Impact your normal processes, affecting your performance on cost measures and
   other administrative claims measures.


IS THERE AN INSTANCE WHEN THE EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
IS AUTOMATICALLY APPLIED?

Yes. MIPS eligible clinicians who are located in a Centers for Medicare &
Medicaid Services (CMS) designated region that has been affected by an extreme
and uncontrollable event (such as FEMA-designated major disaster) during PY 2022
receive the automatic extreme and uncontrollable circumstances exception. We
identify qualifying events through the QPP Listserv. Subscribe at the bottom of
any page on the website.

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

MIPS eligible clinicians identified as affected by the automatic extreme and
uncontrollable event will have all 4 MIPS performance categories reweighted to
0% of their final score, unless they submit data for 2 or more performance
categories. These clinicians are automatically identified and don’t need to
submit an exception application.

If you qualify for the automatic exception and have an approved exception
application, the performance category reweighting from the automatic exception
will supersede any performance category reweighting approved through the
application.


HOW DO I APPLY?

You need a HCQIS Access Roles and Profile (HARP) account to submit a MIPS EUC
Exception application. Once you sign into QPP with your HARP credentials, click
‘Exceptions Application’ on the left-hand navigation and then select ‘Extreme
and Uncontrollable Circumstances.’

For more information on how to obtain a HARP account, refer to the Register for
a HARP Account document in the QPP Access User Guide.  

Updated

The MIPS EUC Exception application deadline for PY 2022 has been extended to
8 p.m. ET on March 3, 2023. This extension is specific to applications submitted
because of the ongoing COVID-19 PHE.


HOW DO I KNOW IF I’M APPROVED?

You'll be notified by email if your request was approved or denied. You can also
check the status of your application by signing into QPP. If approved, this will
also be added to your eligibility profile in the QPP Participation Status
Tool on a rolling basis. If your application is approved at the end of the
application period, you may not see this reflected in your eligibility profile
until early 2023, soon after the submission window opens.


WHAT HAPPENS IF MY APPLICATION IS APPROVED?

If your application is approved, you don’t have to report for the requested MIPS
performance category or categories, and those categories will be reweighted.


CAN I STILL SUBMIT DATA?

Yes. Whether you qualify for automatic reweighting or have an approved exception
application, you can still report data. If you submit data for 2 or more MIPS
performance categories, you’ll receive a final score based on your performance
in these categories.


WHAT ABOUT APM ENTITIES?

APM Entities participating in MIPS APMs can submit a MIPS EUC Exception
application with some differences from our existing policy for individuals,
groups, and virtual groups:

 * APM Entities are required to request reweighting for all performance
   categories
 * At least 75% of the MIPS eligible clinicians in the APM Entity will need to
   qualify for reweighting in the Promoting Interoperability performance
   category
 * Data submission for an APM Entity won't override performance category
   reweighting

You will be notified by email if your request was approved or denied. You can
also check the status of your application by signing into QPP. If approved, this
approval will also be added to your eligibility profile in the QPP Participation
Status Tool on a rolling basis. If your application is approved at the end of
the application period, you may not see this reflected in your eligibility
profile until early 2023, soon after the submission window opens.


MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY HARDSHIP EXCEPTION

Beginning with the 2022 performance period, certified electronic health record
technology (CEHRT) that meets the 2015 Edition certification criteria, 2015
Edition Cures Update certification criteria, or a combination of the two is
required for participation in the Promoting Interoperability performance
category. Under MIPS, you may qualify for reweighting of the Promoting
Interoperability performance category (to 0%) if you meet certain criteria.


CAN I APPLY FOR A MIPS PROMOTING INTEROPERABILITY HARDSHIP EXCEPTION?

Yes. The MIPS Promoting Interoperability Performance Category Hardship Exception
application period for PY 2022 is now available and applications can be
submitted through 8 p.m. ET on January 3, 2023. MIPS eligible clinicians,
groups, and virtual groups may submit a MIPS Promoting Interoperability
Performance Category Hardship Exception application whether
reporting traditional MIPS or the APM Performance Pathway (APP). This
application isn’t available to APM Entities. Hardship exceptions are available
for the following specified reasons:

 * 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

Simply lacking the required CEHRT doesn't qualify you for reweighting.

NOTE: If you're already exempt from submitting Promoting
Interoperability data, you don't need to apply for this application. Learn
more. 


HOW DO I APPLY? 

You need a HCQIS Access Roles and Profile (HARP) account to submit a MIPS
Promoting Interoperability Performance Category Hardship Exception application.
Once you sign into QPP with your HARP credentials, select ‘Exceptions
Application’ on the left-hand navigation and then select ‘Promoting
Interoperability Hardship.’ 

For more information on how to obtain a HARP account, refer to the Register for
a HARP Account document in the QPP Access User Guide.  

You can submit a MIPS Promoting Interoperability Hardship Exception application
for PY 2022 through 8 p.m. ET on January 3, 2023.


HOW DO I KNOW IF I’M APPROVED? 

You'll be notified by email if your request was approved or denied.  You will
also be able to check the status of your application by signing into QPP. If
approved, this will also be added to your eligibility profile in the QPP
Participation Status Tool on a rolling basis. If your application is approved at
the end of the application period, you may not see this reflected in your
eligibility profile until early 2023, soon after the submission window opens.


WHAT HAPPENS IF MY APPLICATION IS APPROVED?

If your application is approved, you don't have to report for the MIPS Promoting
Interoperability performance category, and the category will be reweighted to 0%
of your final score.

The 25% weighting of the Promoting Interoperability performance category will be
redistributed to another performance category (or categories) unless you choose
to submit data. If you submit data, the hardship will be cancelled and your data
will be scored.


WHAT IF I'M A MIPS APM PARTICIPANT?

MIPS eligible clinicians and groups with MIPS eligible clinicians participating
in a MIPS APM can apply for hardship exceptions and qualify for automatic
reweighting just like other MIPS eligible clinicians. If you’re participating in
MIPS at the APM Entity level (either reporting traditional MIPS or the APP), you
will receive the APM Entity’s score, but will be excluded from the calculation
when we create an average Promoting Interoperability score for the APM Entity. 


CAN I STILL SUBMIT DATA?

Yes. Whether you qualify for automatic reweighting or have an approved exception
application, you can still choose to report. If you do submit data, we’ll score
your performance and weight your Promoting Interoperability performance category
at 25% of your MIPS final score. (Note: You will be scored in this performance
category if you attest to any data during submissions, such as selecting
performance period dates or answering measure questions.)

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