How Can You Qualify for the MIPS 2021 Exception Applications?

MIPS (Merit-based Incentive Payment System) is a part of the Quality Payment Program (QPP) for the Medicare Part B healthcare providers. It was so they could get compensated based on their performance.

MIPS 2021 Exception Applications

The MIPS Exception Applications are for the candidates who find it impossible to collect and submit their clinical data and can't perform any actions in that instance.

The exception applications for MIPS 2021 are:

• Exception Application for Extreme and Uncontrollable Circumstances
• Exception Application for Hardships in the MIPS Promoting Interoperability Performance Category

Exception Application for Extreme and Uncontrollable Circumstances

This MIPS exception application is for the medical practitioners, groups, and virtual groups who want the scores of one or all of their MIPS categories reweighed.

Most probably because of unforeseen circumstances or circumstances that make it extremely difficult for them to submit data properly.

For APM Entities

• Alternative Payment Model (APM) Entities can apply for this exception as well but they have to request for reweighing of all the MIPS categories.
• Almost 75% of the entity's physicians who qualify for MIPS participation must be eligible for reweighting in the PI category.
• Even after the data gets sent, it will not cause any changes with the reweighing of the performance category.

COVID-19 and Its Impact

The pandemic has impacted people's lives everywhere, especially those who work in healthcare. Despite that, the extent of it varies from person to person.

Because of this, this exception got extended for another year. It makes it easier for individual healthcare providers, groups, virtual groups, and APM Entities to apply reweighing if necessary due to the ongoing COVID-19 pandemic.

What are the Extreme and Uncontrollable Circumstances for MIPS 2021 Reporting?

Extreme and uncontrollable circumstances are rare events outside the clinician's control or the facility where they practice.

They can cause problems such as:

• Leaving no possibility of collecting the necessary information for the MIPS 2021 performance categories.
• Leave a clinician unable to submit data for an extended period.
• Or affect other regular procedures, like your performance for administrative claims measures such as cost measures.

Can This Exception be Automatically Applied?

It can be applied automatically for eligible practitioners who work in CMS-designated regions and have been affected by the circumstances mentioned above. But it does not apply to group or virtual group participation.

The MIPS 2021 eligible clinicians affected by an extreme event will have all their MIPS categories reweighed to 0% unless they submit data for two or more performance categories. Such specialists don't need to apply for an exception as they get automatically identified.

But remember, an automatic approval means that any performance category reweighting from the exception will supersede the reweighting of the performance category that got approved through an application.

How Can We Apply for this MIPS Exception Application?

If you want to apply for this application, you need an HCQIS Access Roles and Profile (HARP) account.

What is a HARP Account?

HARP is a portal created by CMS, which helps users request CMS applications. They can do it with the username and password they receive to access them.

Just check out the Register For A HARP Account document in the QPP Access User Guide if you don't know how to get a HARP account.

Where Can This Application Be Found?

As soon as you log into your QPP account, you'll be able to see the "Application Exceptions" on the left side of your screen. Just select the "Extreme and Uncontrollable Circumstances" option from there.

The deadline for this exception was December 31st, 2021, at 8 p.m. ET (Eastern Time).

How Will I Know My Application's Status?

If your application is approved or declined, you will receive an email notification. You can also find it out yourself by signing into QPP or taking help from your MIPS Qualified Registry.

You'll be able to view it on your eligibility profile in the QPP Participation Status Tool if it's accepted. And you won't have to report for the specified MIPS 2021 performance category or categories as they will be reweighted.

But remember, if your application gets approved at the end of the performance year, it might not appear until the opening of the submission period in 2022.

Can I Submit Data Even After I have Qualified for Reweighing?

Data can still be reported for the performance categories even if you qualify for automatic reweighting or have an approved exception application. In this case, your final MIPS 2021 score will be based on your performance in the categories whose data you chose to report.

Exception Application for Hardships in the MIPS Promoting Interoperability Performance Category

To participate in the Promoting Interoperability category in MIPS 2021, the candidate needs to be in possession of,

• certified electronic health record technology (CEHRT) that fulfills the 2015 Edition certification criteria or the 2015 Edition Cures Update certification criteria.
• It can also be a combination of both.

After that, you can apply for reweighting of the Promoting Interoperability category if you meet all the requirements.

Who Can Apply for this MIPS Hardship Exception?

Clinicians, groups, and virtual groups eligible for MIPS participation can submit a MIPS Promoting Interoperability Performance Category Hardship Exception Application. It doesn't matter if they will be reporting for the traditional MIPS categories or through the APM Performance Pathway (APP).

For APM Entities

This application isn't available for APM Entities. But clinicians and groups eligible for MIPS participation and are taking part in the MIPS APM can still apply for this exception and qualify for reevaluation. They will receive the APM Entity's score if they participate in MIPS at the APM Entity level through either regular MIPS 2021 reporting or the APP.

However, they will be exempt from the average Promoting Interoperability score calculation for the APM Entity.

What Can be the Reasons to Apply for this MIPS Exception Application?

You can apply for this exception because of the following reasons:

• You own and operate a small practice.
• Your EHR technology is not certified.
• You have issues regarding internet connectivity.
• You are undergoing circumstances that make it impossible to submit data, like a natural disaster, financial issues or distress, your practice closed down, etc.
• You do not have control over the availability of CEHRT, as simply not having the required CEHRT doesn't qualify you for this MIPS exception application.

If you are already exempt from this category, you don't have to be concerned with applying for this exception.

How Can I Apply for this MIPS 2021 Exception Application?

If you want to apply for this exception, you need an HCQIS Access Roles and Profile (HARP) account.

Where Can I Find This Application?

As soon as you log into your QPP account, you'll be able to see the "Application Exceptions" on the left side of your screen.

Just select the "Promoting Interoperability Hardship" option from there.

The deadline for this exception application for 2021 was December 31st, 8 p.m. ET (Eastern Time).

How Will I Be Notified of the Approval or Denial of My Application?

You will know of the approval or denial of your application by email. You can also find it out yourself by signing into QPP.

If your application gets approved, you will see it displayed on your eligibility profile in the QPP Participation Status Tool. And you won't have to report for the MIPS Promoting Interoperability performance category as it will get reweighted to 0%. Its 25% will be transferred or distributed in the other categories.

But remember, if your application gets approved at the end of the performance year, it might not appear until the opening of the submission period in 2022. Also, if you opt to submit the data, the hardship will be canceled, and you will get scored for the data you submitted.

Can I Submit Data Even After I Have Qualified for Reweighing?

Even if you have been approved for an exception or qualify for automatic reweighing, you can still submit data for his category. It will get evaluated, and the weight of this category will be the usual 25% of the final MIPS 2021 score.

Also, you will get scored in this category only if you can prove you submitted data for evaluation, like selecting performance period dates.

Read more: CMS Updated the QPP MIPS APM Participation Status