MIPS 2020 Hardship Exception Application

How to Apply for a MIPS 2020 Hardship Exception

The Merit-Based Incentive Payment Program (MIPS) is now in its fourth year. Due to the COVID-19 public health emergency (PHE), the Centers for Medicare & Medicaid Services (CMS) is “implementing multiple flexibilities” for the Quality Payment Program (QPP) and has invoked an “Extreme and Uncontrollable Circumstances Exception” policy for the MIPS 2020 performance year.

Not sure if you qualify for a MIPS 2020 hardship exception or how to check your MIPS participation status? Here’s a quick recap of answers to frequently asked questions about applying for MIPS 2020 hardship exceptions during the pandemic PHE.

What is the deadline for submitting a MIPS 2020 hardship application?

Depending on the type of MIPS 2020 hardship application you submit, there are two application deadlines for eligible clinicians (EC), groups, and virtual groups.

  • Extreme and Uncontrollable Circumstances Application: CMS has extended the application deadline to February 1, 2021, 8:00 pm Eastern Time. CMS will notify applicants via email whether their requests are approved or denied.
  • Promoting Interoperability Performance Category Hardship Exception Application: The application deadline is December 31, 2020, 8:00 pm Eastern Time. If you are already exempt from reporting Promoting Interoperability data, you do not need to apply for this exception.

What hardship exceptions are available for MIPS 2020?

There are two MIPS 2020 exception applications available for eligible clinicians, groups, and virtual groups for performance year 2020.

  1. Extreme and Uncontrollable Circumstances Exception Application. Eligible clinicians and groups can request reweighting one or more MIPS 2020 performance categories (Quality, Cost, Promoting Interoperability, and Improvement Activities) to 0% due to extreme and uncontrollable COVID-19 circumstances. For more information, refer to the 2020 QPP Exceptions Application Fact Sheet.
  2. Promoting Interoperability Performance Category Hardship Exception Application. Eligible clinicians and groups can request reweighting the Promoting Interoperability performance category to 0% if they meet the following criteria:
    • Have a small practice (a TIN or virtual group with 15 or fewer eligible clinicians)
    • Have decertified EHR technology
    • Have insufficient internet connectivity
    • Face extreme and uncontrollable circumstances (disaster, practice closure, or financial distress)
    • Lack of control over the availability of certified electronic health record technology (CEHRT)

IMPORTANT REMINDER: If you submit an exception application as a group, every eligible clinician in the group must meet the exception criteria.

Do you need a HARP account to submit a hardship exception?

Before you can apply for a MIPS 2020 hardship exception, you will need to create an account (if you haven’t done so already) with HCQIS Access Roles and Profile (HARP). HARP uses Experian to verify your identity. You will need your HARP credentials to sign in to your QPP account when applying for a MIPS exception.

Once you register and sign in to your QPP account, select “Exceptions Applications” on the left-hand side navigation. Then select “Add New Exception” and select “Extreme and Uncontrollable Circumstances Exception” or “Promoting Interoperability Hardship Exception.”

What happens if the MIPS 2020 exception application is approved?

If CMS approves an exception application(s), CMS will add your exception to the QPP Participation Status Tool. But the exception may not appear until the MIPS 2020 submission window opens on January 4, 2021 (date subject to change).

For example, if you successfully apply to have three or four performance categories reweighted to 0% and CMS approves the application, CMS will assign you a 2020 MIPS final score of 45 points. The 45 points will still allow you to avoid a MIPS payment penalty in 2021, but you will not receive a bonus payment.

What if you don’t submit a MIPS 2020 exception application?

All eligible clinicians, groups, and virtual groups who do not submit a hardship exception application by December 31, 2020, will be responsible for submitting data to CMS for applicable MIPS categories for performance year 2020.

The only exception to participating in MIPS 2020 is unless the eligible clinician or group is exempt from MIPS (such as they do not reach the MIPS 2020 low-volume threshold).

What is the MIPS performance low-volume threshold?

To qualify for the MIPS low-volume threshold (LVT), individual eligible clinicians and groups are exempt from the MIPS 2020 reporting period if they meet or exceed at least one of the following LVT criteria:

  • Bill less than or equal to $90,000 in Medicare Part B allowable charges for covered professional services,
  • Provide covered professional services to less than or equal to 200 Medicare Part B beneficiaries, or
  • Provide less than or equal to 200 covered professional services to Part B beneficiaries under the Medicare Physician Fee Schedule (PFS).

How can you check your MIPS 2020 participation status?

Check your MIPS participation status on the Quality Payment Program (QPP) website using the QPP Participation Status Tool. Enter your 10-digit National Provider Identifier (NPI) number to view your MIPS participation status for performance year 2020.

QPP Participation Status

Graphic Source: CMS Quality Payment Program

MIPS 2020 Industry Resources

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This blog was updated on December 2, 2020.