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CMS Opens Quality Payment Program Hardship Exception Application

CMS is now accepting Quality Payment Program hardship exception applications for the 2017 transition year.

Quality Payment Program

Source: Thinkstock

By Kate Monica

- Applications for Quality Payment Program (QPP) Hardship Exceptions are now open for eligible clinicians participating in the 2017 transition year, CMS announced.

The federal agency issued the announcement in a recent listserv email.

Clinicians and groups eligible to attest under the Merit-Based Incentive Payment System (MIPS) may qualify for a reweighting of their Advancing Care Information (ACI) performance category score to zero percent of the final score.

These individuals or groups of clinicians can submit a hardship exemption application for any of the following specific reasons: 

  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of Certified EHR Technology (CEHRT)

“The 25 percent weighting of the advancing care information performance category would be reallocated to the quality performance category,” clarified CMS on the official QPP website. “Simply lacking CEHRT does not qualify the MIPS-eligible clinician or group for reweighting.”

The federal agency also specified that some MIPS eligible clinicians considered “Special Status” will automatically be reweighted or exempted if they are participating in a MIPS APM. Special Status eligible clinicians are not required to submit a QPP Hardship Exception Application.

According to the CMS QPP website, Special Status clinicians include the following: 

  • Hospital-based MIPS-eligible clinicians
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Non-patient facing clinicians
  • Proposed in Quality Payment Program Year 2: Ambulatory Surgical Center (ASC) Based MIPS-Eligible Clinicians

In addition to the online application option, eligible clinicians can contact the QPP Service Center and work with a CMS representative to submit an application verbally.

Applications are subject to annual renewal.

The EHR Incentive Program Hardship Exception Application is also available for eligible professionals (EPs) participating in the Medicare EHR Incentive Program for the first time in 2017.

This exception considered a one-time hardship exception.

First-time EPs can apply for the one-time hardship exception to avoid a 2018 payment adjustment for any of the following reasons, according to CMS: 

  • The EP is a first-time participant in the EHR Incentive Program in CY 2017 and intends to participate in the Medicare EHR Incentive Program in CY 2017, and 
  • The EP is transitioning to MIPS for the 2017 performance period, and
  • The EP intends to report on measures specified for the Advancing Care Information performance category under the MIPS in 2017.

Applications for the EHR Incentive Program Hardship Exception are due by October 1, 2017.

This development follows the announcement that CMS has finalized several revisions to the meaningful use requirements for eligible providers participating in the EHR Incentive Programs next year.

Most significantly, CMS has reduced the EHR reporting period in 2018 to 90 days for “new and returning participants attesting to CMS or their Stage Medicaid agency,” according to the final rule slated for publication on August 14.

CMS has chosen to finalize these revisions to 2018 meaningful use requirements in an effort to continue the advancement of certified EHR technology utilization with a particular focus on interoperability and health data exchange.

Most of the finalized changes correspond to mandates included in the 21st Century Cures Act, including an exception for Medicare payment adjustments for EPs and hospitals affected by EHR decertification. 

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