CMS Deadline for Hardship Exception to QPP 2018 Program Interoperability is December 31, 2018

CMS continues to emphasize that any individual QPP-eligible practitioner or those in a small group (15 or fewer Medicare providers) who are having issues with the 2018 Program Interoperability area of the Quality Payment Program (QPP) – such as those whose EMR was “de-certified” this year or who have other exceptional difficulties doing this for 2018 reporting – can apply for an hardship exception for this area of QPP.  The deadline for submission of this application is December 31, 2018 for the 2018 reporting year.

CMS notes that if the exception is granted, this category’s weight (25% of the total) will be moved to Quality which would be 75% instead of 50%.  This means that the maximum possible QPP composite score of 100 can still be achieved.

As a small practice, you can access the CMS exception application link here.  Once you access it, use the drop-down to choose “Promoting Interoperability Hardship Application.  Since this only applies to individual providers or small groups, when you get to section 2, choose “Section 2.5 Small Practice” and then complete the application.   Once it is complete, click the SUBMIT area which will be in the bottom right of this final page.

Although it is more unlikely, CMS states that even larger practices (16 or more providers) can still apply for this hardship if they meet one of these small list of criteria:

  • Lack of control over certified electronic health record technology (CEHRT)
  • De-certification of the practice’s CEHRT
  • Extreme and uncontrollable circumstances
  • Insufficient Internet connectivity

CMS notes that this does not apply to those groups and individual providers who are already automatically excluded from the entire QPP in 2018 (like those who practices lie entirely in the hurricane- and fire-affected areas this year).  We noted that in a separate news posting (link here) which has more information.

We are happy to assist providers and groups in any way with other topics including MIPS in general, 2018 MIPS attestations, as well as proper code selection, chart reviews, payer action questions – please contact us.  We can also provide training on these or other subjects.  You can reach us via the link to our main webpage or at the phone number below.

You can also download our “App”, Corcoran 24/7, which can be separately accessed via one of the links below. (800) 399-6565

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