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MIPS 2019, CMS, MIPS QPP, MIPS Quality measure, PI Exception

All about the MIPS 2019 Hardship Exception Rules

CMS expects eligible clinicians to perform well in MIPS QPP.  Sometimes despite the efforts, physicians are unable to meet even the minimum performance threshold.

We can’t blame them if they happen to suffer from unexpected hardships such as severe weather conditions or other unfavorable situations. CMS offers relaxation for such cases.

The time for sending applications for MIPS 2019 exceptions has been started. Eligible clinicians, groups, and virtual groups now can apply in the exception context in two categories.

  • Promoting Interoperability (PI) Hardship Exception
  • Extreme and Uncontrollable Circumstances Exception

Exceptions will be offered only to those, who fulfill the criteria as specified by the CMS. Also, clinicians or groups who fall in the category of automatic reweighting of PI reporting shouldn’t have to apply for an exception.

MIPS 2019 Promoting Interoperability (PI) Hardship Exception

To submit for MIPS 2019 Promoting Interoperability (PI) measure, physicians must have access to 2015 Certified Electronic Health Record Technology (CEHRT).

The net weight of the PI category is 25% of the total MIPS score. Clinicians unable to report in this measure will have their percentage shifted to the MIPS Quality measure category.

Who Can Apply for PI Exception?

The mere absence of 2015 CEHRT will not grant any relaxation for PI data submission.

However, if you suffer from any of the below-mentioned scenarios, you qualify the PI hardship exception criteria.

  • Inadequate/Unsatisfactory Internet connectivity
  • No Control over the access of CEHRT
  • Extreme and Controllable Circumstances
  • De-certified EHR technology
  • A small medical practice with fifteen or lesser clinicians with the same Tax identification number

There are special cases in which eligible physicians are already exempt from the PI category, and are not required to submit hardship exception application of any sort.

For MIPS 2019, Clinicians with special cases are:

  • Non-Patient Facing clinicians
  • Hospital-based MIPS eligible clinicians
  • MIPS eligible clinicians associated with Ambulatory Surgical Center (ASC)
  • Nurse practitioners, physician assistants, certified registered nurse anesthetists, clinical nurse specialists
  • Physical therapists, registered dietitians, occupational therapists, speech-language pathologists, clinical psychologists, audiologists, and nutrition professionals

Note: If you participate in MIPS 2019 as a group, all members should apply for a hardship exception to reweight the PI score for the group.

Extreme and Uncontrollable Circumstances Exception

CMS states that extreme and uncontrollable conditions refer to the cases in which you have no control over anything or the facility in which you work.

By coming across such situations,

  • Clinicians may be unable to collect data for PI category
  • Clinicians may be unable to submit data to CMS for a long time (For any performance category)

In case of such circumstances, eligible medical practitioners as either individuals or groups can apply for an exception in all of the four categories.

  • Quality
  • Cost
  • Improvement Activities (IA)
  • Promoting Interoperability (PI)

Upon requesting an exception, clinicians must report the category, which was affected by the extreme conditions along with the impact.

Required Information

Eligible clinicians and groups must have the following information:

  • For Virtual Group: VG ID
  • For Group: Group name & TIN (Tax Identification Number)
  • For Individual clinicians: Clinician’s NPI (National Provider Identifier), Group Name, Group TIN

How to Send Application?

Clinicians and groups can send their applications via the official QPP website. The applications must be sent out before December 31, 2019.

Either CMS approves or disapproves of your request for an exception; CMS will notify you. The approval status will also be updated on the physician’s profile (QPP Participation Status Tool).

There’s only a little time left to submit an application for MIPS 2019 hardship exception. Although, CMS doesn’t require supporting data for the application. But, it is advisable to retain any important information in case CMS asks for it (for validation or audit).

Learn about 3 Points to Consider Before MIPS 2019 Reporting!

MIPS 2019 Reporting, MIPS qualified registries, MIPS QPP, MIPS Quality Measure, MIPS consulting services

3 Points to Consider Before MIPS 2019 Reporting

Physicians! It’s time to prepare for the MIPS 2019 reporting period. There’s only a little time left.

This time may be hectic and stressful, even for MIPS qualified registries. But don’t worry, P3 Healthcare Solutions has come up with effective tips to target high MIPS scores.

Let’s be honest, MIPS QPP can be a daunting approach to earn incentives for those who are not careful.

On the other hand, it can be rewarding and tends to appreciate clinicians’ efforts for showing remarkable performance.

Now, the bad performance can’t be blamed over a misunderstanding. It’s been three years since MIPS if you still can’t perform well, you should expect financial setback.

Financial Risk Is Increasing!

  • This year, the performance threshold is thirty points.
  • Financial risk is up to 7%.

You can imagine that the reporting complexities will be higher than the years before. Some people will win this game while others will lose. The only way forward is to strategize beforehand and report according to the specified guidelines.

So, just let’s dig into three important points to consider before MIPS 2019 reporting.

Understand the Criteria for the Minimum Performance

Did you know that only by correctly reporting for Improvement Activities (IA) and Promoting Interoperability (PI) categories can give points up to 40? It is at least 10 points more than the minimum threshold that can save from the penalty.

Speaking about the reporting strategy, keep in mind that this year, PI category data submission has especially been strict. Now, it’s not enough to just say that yes! I did it. You have to provide substantial evidence for the performance.

Pay Attention to MIPS Quality Measure

You might be thinking that if reporting for just IA and PI is enough to save your face, why not just stop there.

But we suggest, NO! You should not only be considering penalties but the goal should be incentives and bonuses.

Striving for better opportunities gives margin to stay ahead of game from others who might have done something to prevent themselves from penalties.

So, working not only to save yourself but to earn incentives and bonuses should be included in strategies, and reporting for MIPS quality measures is an efficient way to do that.

Don’t Wait for the End Time for Data Submission

CMS – The Centers for Medicare and Medicaid require data for 90 days of PI and IA performance categories. The same is not the case with Quality and Cost measures.

CMS also has a specified timeline in which eligible clinicians can report data to them. However, if you consult a MIPS qualified registry, you are able to save data and make relevant changes from time to time.

This strategy reduces the chances of errors, data redundancy, and saves time. MIPS is a bit complex, but the key to success is to comprehend the reporting criteria, which is an easy process when collaborated with MIPS consulting services.

Small medical practices or hospitals need their time to plan, but a smart strategy can go a long way to maximize returns, optimize time, and efforts.

So, start planning today.

Learn about MIPS quality measures specifications 2019 in a nutshell.