CMS Opens Applications for Hardship Exceptions in the Quality Payment Program (QPP)

The Centers for Medicare & Medicaid (CMS) has opened the application period for two different types of hardship exceptions under the Quality Payment Program, for the performance year 2020.  If either were granted, they would change practices’ scoring and penalties in payment year 2022.  Both types of hardship exception applications and information can be accessed on the QPP webpage at this link.  They note that the application page, while open now, will remain open until December 31, 2020.  Importantly, you’ll need a HARP account to access the QPP application page for either exception.  Here is a link to that process from a prior CCG WebNews that describes HARP setup.

The first exception applies only to the MIPS Promoting Interoperability (PI) area.  CMS also notes that merely “Lacking CEHRT does not qualify you [for the exception]” and that those already exempt from PI (ASCs, PAs, NPs and a few others) do not need to apply.

CMS notes the following as reasons you might apply for the PI exception:

 You’re a small practice

  • You have decertified EHR technology
  • You have insufficient Internet connectivity
  • You face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
  • You lack control over the availability of CEHRT

The second exception applies to the entire QPP program under the “Extreme and Uncontrollable Circumstances”.  CMS notes these are “rare events entirely outside of your control and the control of the facility in which you practice”.  The impact of COVID-19 on clinical and surgical operations might qualify a number of practices.  If this exception is granted and you choose not to submit in 2020, you would not be penalized in 2022 but could earn no bonus.

CMS lists the following as causes for which you might seek this wider exception:

  • … unable to collect information necessary to submit for a MIPS performance category;
  • … unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the Quality performance category for 3 months), and/or;
  • Impact your normal processes, affecting your performance on cost measures and other … measures.

We are available and happy to assist you with issues such as this and other topics related to eye care.  Stay safe. (800) 399-6565

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