CMS Releases Hardship Applications for ACI Category of MIPS

August 4, 2017

This week the Centers for Medicare & Medicaid Services (CMS) released information about the hardship exemption process for the Advancing Care Information Category of the Quality Payment Program (QPP) Merit-Incentive Base Payment System (MIPS). To apply you need to visit the Quality Payment Program website. As a reminder, the ACI category is worth 25 percent of the overall MIPS score for all eligible clinicians that bill part B services regardless of their practice setting. ECs that practice in skilled nursing facilities may have a difficult time meeting the ACI requirements and would have to fill out the application to receive this exemption. The 25 percent of the score would then be reweighed into the Quality category which is currently worth 60 percent of the overall score (would become 85 percent of ACI is reweighed).

MIPS eligible clinicians and groups may qualify for a reweighting of their ACI performance category score to 0% of the final score, and can submit a hardship exception application, for one of the following specified reasons:

  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of Certified EHR Technology (CEHRT) – Note: Many Society members will qualify for this exemption.

There are some MIPS eligible clinicians who are considered Special Status, who will be automatically reweighted (or, exempted in the case of MIPS eligible clinicians participating in a MIPS APM) and do not need to submit a Quality Payment Program Hardship Exception Application.

About the Hardship Exception Application Process

In addition to submitting an application via the Quality Payment Program website, clinicians may also contact the Quality Payment Program Service Center and work with a representative to verbally submit an application.

To submit an application, you’ll need:

  • Your Taxpayer Identification Number (TIN) for group applications or National Provider Identifier (NPI) for individual applications;
  • Contact information for the person working on behalf of the individual clinician or group, including first and last name, e-mail address, and telephone number; and
  • Selection of hardship exception category (listed above) and supplemental information.

If you’re applying for a hardship exception based on the Extreme and Uncontrollable Circumstance category, you must select one of the following and provide a start and end date of when the circumstance occurred:

  • Disaster (e.g., a natural disaster in which the CEHRT was damaged or destroyed)
  • Practice or hospital closure
  • Severe financial distress (bankruptcy or debt restructuring)
  • EHR certification/vendor issues (CEHRT issues)

Please note: Once an application is submitted, you will receive a confirmation email that your application was submitted and is pending, approved, or dismissed. Applications will be processed on a rolling basis.