CMS Opens Hardship Exemptions for MIPS 2017

The Centers for Medicare & Medicaid (CMS) opened the hardship application process for 2017 MIPS reporting of the Advancing Care Information (ACI) portion of the MIPS Composite Score on August 2, 2017.  ACI applies to that section of MIPS where certified EHR technology applies; it was formerly known as the Meaningful Use (MU).  CMS notes:

“MIPS-eligible clinicians and groups may qualify for a reweighting of their advancing care information performance category score to 0 percent of the final score if they meet the criteria outlined below. The 25 percent weighting of the advancing care information performance category would be reallocated to the quality performance category. Simply lacking CEHRT does not qualify the MIPS-eligible clinician or group for reweighting …”

CMS notes that 3 reasons to apply for the ACI hardship exemption are:

  • Insufficient Internet Connectivity
  • Extreme and Uncontrollable Circumstances
  • Lack of Control over the availability of CEHRT

They also note that there are some clinicians who are deemed to be “Special Status” and do not have to apply for the exemption.  CMS notes they are automatically re-weighted.  Some of those clinicians are:

  • Hospital-based MIPS-eligible clinicians
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Non-patient facing clinician


Link here to the CMS Hardship Exception webpage for more information.  To access the electronic CMS Hardship application, link here.  It is submitted directly to CMS electronically by clicking the “Submit” button at the bottom right, so be sure to save a copy or print your submission before clicking.  Applying for the hardship exemption now does NOT mean that a practice cannot submit information under ACI – but they also note that if ACI numbers are submitted, they WILL BE scored.

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