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Merit-based Incentive Payment System (MIPS) 2022 MIPS Promoting Interoperability Performance Category Hardship Exception Application Guide 1 Contents How to Use This Guide Already know what MIPS is? Skip ahead by clicking the links in the Table of Contents. 3 MIPS Promoting Interoperability Performance Category Hardship Exception App lication Overview 5 MIPS Promoting Interoperability Performance Category Hardship Exception Info rmation for Individuals, Groups, and Virtual Groups 7 MIPS Promoting Interoperability Performance Category Hardship Exception: Fre quently Asked Questions 12 MIPS Promoting Interoperability Performance Category Hardship Exception: Ap plication Steps 14 Help, Resources, Glossary, and Version History 30 Appendix 34 2 How to Use This Guide 3 How to Use This Guide Table of Contents The table of contents is interactive. Click on a chapter in the table of contents to read that section. You can also click on the icon on the bottom left to go back to the table of contents. Please note: This guide was prepared for informational purposes only and isn’t intended to grant rights or impose obligations. The information provided is only intended to be a general summary. It isn’t intended to take the place of the written law, including the regulations. We encourage readers to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents. Hyperlinks Hyperlinks to the Quality Payment Program website are included throughout the guide to direct the reader to more information and resources. Purpose: This guide will provide general information about the MIPS Promoting Interoperability Performance Category Hardship Exception application and provide step-by-step instructions on how to complete the application. 4 MIPS Promoting Interoperability Performance Category Hardship Exception Application Overview 5 MIPS Promoting Interoperability Performance Category Hardship Exception Application Overview Overview What Who Why When Where How MIPS Promoting Interoperability Hardship Exception applications allow you to request that your MIPS Promoting Interoperability performance category be reweighted to 0%. Individual clinicians, groups, and virtual groups reporting via traditional MIPS or the APM Performance Pathway (APP) • Third Party Intermediaries can submit an application with permission from the clinician or practice. Some clinicians, groups and virtual groups automatically qualify for reweighting of the Promoting Interoperability performance category. If you qualify for automatic reweighting, you don’t need to apply for a MIPS Promoting Interoperability Hardship Exception. • See Appendix A for information about the clinicians, groups and virtual groups that automatically qualify for reweighting of this performance category. You can submit an application to have your MIPS Promoting Interoperability performance category reweighted to 0% Note: We automatically reweigh Promoting if: Interoperability for small practices. See page 8 for more information. • You have insufficient Internet connectivity • You have decertified EHR technology • You lack control over the availability of CEHRT o Lacking 2015 Edition CEHRT doesn’t qualify as a reason to submit an exception application • You face extreme and uncontrollable circumstances such as a disaster, practice closure, severe financial distress or vendor issues o If you experience an extreme and uncontrollable circumstance that impacts multiple performance categories, the Extreme and Uncontrollable Circumstances exception application may be more suitable for your given circumstance. Now through January 3, 2023, at 8 p.m. ET. Sign in to qpp.cms.gov with your HCQIS Access and Roles Profile (HARP) account. • For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide (ZIP). 1. Register for a HARP account 2. Sign in to qpp.cms.gov 3. Select ‘Exceptions Application’ on the left-hand navigation SeeSelect Appendix (traditional MIPS) and Appendix C (APP) for more information on performance category 4. ‘Add B New Exception’ 6 5. Select ‘Promoting Interoperability Hardshipreweighting. Exception’ MIPS Promoting Interoperability Performance Category Hardship Exception Information for Individuals, Groups, and Virtual Groups 7 MIPS Promoting Interoperability Performance Category Hardship Exception Information for Individuals, Groups, and Virtual Groups Overview You may automatically qualify for reweighting in this performance category. New: Small practices now qualify for automatic reweighting. • See Appendix A. • If you automatically quality for reweighting, you don’t need to submit an exception application. You will complete the hardship exception application at the level for which you will report data to MIPS. • If you are reporting data at the individual level, complete the hardship exception application at the individual level. • If you are reporting data at the group level, complete the hardship exception application at the group level. • Note, a group hardship exception application will only apply at the group level. • If your practice is participating in MIPS at the individual level, don’t complete the hardship exception application at the group level. You will complete the hardship exception application at the individual level for each clinician (who doesn’t automatically qualify for reweighting) to be considered for reweighting. You can still submit data for the MIPS Promoting Interoperability performance category. • If your circumstances change and you’re able to collect and submit your Promoting Interoperability data, we will disregard your hardship exception application and you will be scored in this performance category. • You will also be scored in this performance category if you attest to any data, such as selecting performance period dates or responding to attestation statements, during the submission period. • Starting with performance year 2022, small practices qualify for automatic reweighting of the Promoting Interoperability performance category. You aren’t required to submit documentation with your application. • However, clinicians, groups and virtual groups should retain documentation of their circumstances supporting their application for their own records in the event they are selected by CMS for data validation or audit. See our 2022 MIPS Data Validation Criteria Guide (ZIP) for details on the data validation process. 8 MIPS Promoting Interoperability Performance Category Hardship Exception Information for Individuals, Groups, and Virtual Groups Overview (continued) You can apply for a MIPS Promoting Interoperability performance category hardship exception if you switch CEHRT vendors during the performance period. • You would indicate an extreme and uncontrollable circumstances hardship exception and select vendor issues within the application. The following circumstances qualify as extreme and uncontrollable circumstances for a MIPS Promoting Interoperability performance category hardship exception: • A natural disaster resulting in damage to or destruction of your CEHRT • Practice closure • Severe financial distress resulting in bankruptcy or debt restructuring • Vendor issues (such as a change in vendors during the performance period or errors with your CEHRT that your vendor is unable to address) You may still be able to report if your electronic health record (EHR) product is decertified during the 2022 performance year. • You can still submit your Promoting Interoperability performance category measures collected in your now-decertified EHR product if your performance period ended before the decertification occurred. • If your performance period ended after the EHR decertification occurred, you can apply for a MIPS Promoting Interoperability performance category hardship exception and select decertified EHR technology. 9 MIPS Promoting Interoperability Performance Category Hardship Exception Information for Individuals, Groups, and Virtual Groups Groups and Virtual Groups To submit an application on behalf of a group, every office location/practice site within the Taxpayer Identification Number (TIN) must experience the hardship for the group to qualify for the Promoting Interoperability performance category hardship exception. • For example, if one office location is within a broadband availability area but the other office(s) for the practice is not, the office with broadband availability would not qualify for the MIPS Promoting Interoperability performance category hardship and must report for those clinicians for whom they have data. To submit an application on behalf of a virtual group, every office location/practice site for each TIN within the virtual group must experience the hardship for the virtual group to qualify for the Promoting Interoperability performance category hardship exception. • For example, if one TIN is within a broadband availability area but the other TIN(s) in the virtual group is not, the TIN with broadband availability would not qualify for the MIPS Promoting Interoperability performance category hardship and must report for those clinicians for whom they have data. 10 MIPS Promoting Interoperability Performance Category Hardship Exception Information for Individuals, Groups, and Virtual Groups MIPS APM Participants MIPS eligible clinicians and groups with MIPS eligible clinicians participating in a MIPS APM can apply for hardship exceptions and qualify for automatic reweighting just like other MIPS eligible clinicians. If you’re participating in MIPS at the APM Entity level (either reporting traditional MIPS or the APP), you would complete the application as an individual or group. • If approved, the clinician will receive the APM Entity’s score, but will be excluded from the calculation when we create an average Promoting Interoperability score for the APM Entity. APM Entities reporting the APP or traditional MIPS can’t submit a Promoting Interoperability hardship exception application on behalf of the entire Entity. • When participating in MIPS as an APM Entity, the Promoting Interoperability performance category is still reported at the individual or group level. A MIPS Promoting Interoperability performance category hardship exception doesn’t exempt you from reporting on any certified EHR technology (CEHRT) activities required for participation in your APM. 11 MIPS Promoting Interoperability Performance Category Hardship Exception: Frequently Asked Questions 12 MIPS Promoting Interoperability Performance Category Hardship Exception: Frequently Asked Questions Question Where Can I Look for a Status Update on Our MIPS Promoting Interoperability Performance Category Hardship Exception Application? Answer You can monitor your application status in your QPP Account on qpp.cms.gov. Yes, you can add additional staff or representatives who should receive notifications about the status of the application. Can Additional Staff Members Access/Receive Notifications About the Status of the MIPS Promoting Interoperability Performance Category Hardship Exception Application? How Can I Correct a Mistake Made on Our MIPS Promoting Interoperability Performance Category Hardship Exception Application? In the Additional Access section of the application, provide the email address(es) of additional staff or representatives who would like to receive email notifications. Please note: the additional staff or representatives must have HARP credentials in order to see the application on qpp.cms.gov. If you identified an error with your exception application, please contact the Quality Payment Program at 1-866-288-8292, Monday through Friday, 8 a.m.-8 p.m. ET or by e-mail at: [email protected]. 13 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps 14 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 1: Sign in to Your QPP Account Sign in to your QPP Account at qpp.cms.gov with your HARP credentials. Note: If you haven’t signed into qpp.cms.gov before, you must register for an account to obtain your HARP credentials. See our QPP Account Access Guide (ZIP) for information on creating an account. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 15 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 2: Navigate to Your Exception Applications Once you are signed into your account select: • The Exception Application tab in the left-hand navigation menu, then click + Add New QPP Exception OR • The Start an Application quick link on the home page. You can create and submit a new exception request until 8 p.m. ET on January 3, 2023. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 16 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 3: Select the Exception Application Select the MIPS Promoting Interoperability Performance Category Hardship Exception, then Continue. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 17 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 4: Select Application Type Select the participation level at which you intend to participate in MIPS, then select Save & Continue. (Image features application at the individual level) *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 18 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 5: Enter Participation Level Information Enter the required participation level information. The required information for each participation level is as follows: Participation Required Information Level • National Provider Identifier Individual Clinician (NPI) • Practice Affiliation • Taxpayer Identification Group Number (TIN) Virtual Group • Virtual Group Identifier (Image features application at the individual level) *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 19 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 6: Enter Submitter Details Enter your contact information (as the submitter) and identify your relationship to the party identified in the application. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 20 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 7: Enter Additional Staff in Additional Access Section You can identify additional users to receive notifications about the application in the Additional Access section. If there’s a HARP account associated with the email address(es) you provide, the person will be able to sign in to their own account on qpp.cms.gov and access the application. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 21 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 8: Select the Reason for MIPS Promoting Interoperability Hardship Select the option that aligns with your reason for submitting an MIPS Promoting Interoperability Hardship exception application. Note: You don’t need to submit supporting documentation with your application. However, you should retain documentation of the circumstances supporting your application for your own records in case you are selected by CMS for data validation or an audit. See our 2022 MIPS Data Validation Criteri a Guide (ZIP) for details on the data validation process, *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 22 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 9: Complete Attestation and Provide Event Description Before submitting your application, you must complete the attestation (differs for each reason option). • Insufficient Internet Connectivity • Extreme and Uncontrollable Circumstances • Lack of Control Over the Availability of CEHRT • EHR Decertification You also can provide an optional brief description on the hardship you experienced and how performance data is impacted. 23 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 9: Complete Attestation and Provide Event Description (continued) Reason Option 1: Insufficient Internet Connectivity Review the attestation statement and select “I attest.” You can provide an optional description of the hardship event. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 24 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 9: Complete Attestation and Provide Event Description (continued) Reason Option 2: Extreme and Uncontrollable Circumstances Select the extreme and uncontrollable event type that applies to you, enter event dates, then review the attestation statement and select “I attest.” You can provide an optional description of the hardship event. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 25 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 9: Complete Attestation and Provide Event Description (continued) Reason Option 3: Lack of Control Over the Availability of CEHRT Review the attestation statement and select “I attest.” You can provide an optional description of the hardship event. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 26 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 9: Complete Attestation and Provide Event Description (continued) Reason Option 4: EHR Decertification Enter the date that your EHR was decertified and your ONC-ACB Certification ID. Then, review the attestation statement and select “I attest.” You can provide an optional description of the hardship event. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 27 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps Step 10: Submit MIPS Promoting Interoperability Hardship Application Once you are done with your application, review the disclosures, then select Certify & Submit. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 28 MIPS Promoting Interoperability Performance Category Hardship Exception: Application Steps MIPS Promoting Interoperability Hardship Application Submission Confirmation After you submit your MIPS Promoting Interoperability Hardship application, you will receive a message stating that your hardship application has been successfully submitted and is pending review. You will also receive an email notification. See Appendix D for information on the various application statuses. *The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate feedback and improve experience, there may be differences between these screenshots and what you see on qpp.cms.gov. 29 Help, Resources, Glossary, and Version History 30 Help, Resources, and Version History Where Can You Go for Help? Contact the Quality Payment Program at 1-866-288-8292, Monday through Friday, 8 a.m.8 p.m. ET or by e-mail at: [email protected]. • Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant. Visit the Quality Payment Program website for other help and support information, to learn more about MIPS, and to check out the resources available in the Quality Payment Program Reso urce Library . 31 Help, Resources, Glossary, and Version History Additional Resources The QPP Resource Library houses fact sheets, measure specifications, specialty guides, technical guides, user guides, helpful videos, and more. We will update this table as more resources become available. • 2022 MIPS Promoting Interoperability Quick Start Guide (PDF) • 2022 MIPS Promoting Interoperability User Guide (PDF) • 2022 Extreme and Uncontrollable Circumstances Exception Application Guide (PDF) 32 Help, Resources, and Version History Version History If we need to update this document, changes will be identified here. Date Description 10/06/2022 Updated deadline to request an exception to January 3, 2023, at 8 p.m. ET (slides 6 and 16) 05/02/2022 Original Posting. 33 Appendix 34 Appendix Appendix A. Automatic Reweighting in the MIPS Promoting Interoperability Performance Category Reason for Reweighting (Individual Clinicians) You have one of these Special Statuses: • (New) Small Practice; • Ambulatory Surgical Center (ASC)-based; • Hospital-based; or • Non-patient facing • (New) Clinical social • Physical therapist worker Occupational You are one of these clinician•types: • Physician assistant therapist • Nurse practitioner • Qualified speech• Clinical nurse language pathologist • specialist Qualified audiologist • Certified registered • Clinical psychologist • Registered dietitian or nurse anesthetist nutrition professional Action Needed by the Individual None – You are automatically excepted from having to submit data for this performance category as an individual, though you may still choose to do so. You will be scored in this performance category if your practice is participating as a group or virtual group and doesn’t qualify for reweighting. None – You are automatically excepted from having to submit data for this performance category as an individual, though you may still choose to do so. You will be scored in this performance category if your practice is participating as a group or virtual group and doesn’t qualify for reweighting. Reason for Reweighting (Groups and Virtual Groups) Action Needed by the Group or Virtual Group You have one of these Special Statuses: • Ambulatory Surgical Center (ASC)-based. • Hospital-based: o Group or virtual group must have more than 75% You will be scored in this performance category if your practice is participating as a group or virtual group and doesn’t qualify for reweighting. of clinicians designated as hospital-based. • Non-patient facing: o Group or virtual group must have more than 75% of clinicians designated as non-patient facing. All of the MIPS eligible clinicians in your group or virtual group qualify for reweighting as individuals (through any combination of special statuses, clinician type, and You will be scored in this performance category if your practice is participating as a group or virtual group and doesn’t qualify for reweighting. 35 Appendix Appendix B. MIPS Performance Category Weight Redistribution Policies Under Traditional MIPS Finalized for the 2022 Performance Year: Individual Clinicians, Groups and Virtual Groups Refer to Appendix C for reweighting policies that apply to APM Entities. The table below illustrates the 2022 performance category weights and reweighting policies that CMS will apply to clinicians, groups, and virtual groups reporting via traditional MIPS. Important Reminders: • Individual Clinicians, Groups, Virtual Groups: If fewer than 2 performance categories can be scored (meaning 1 performance category is weighted at 100%, or all performance categories are weighted at 0%), the clinician, group, or virtual group will receive a final score equal to the performance threshold and the MIPS eligible clinicians will receive a neutral payment adjustment in the 2024 payment year. MIPS Performance Category Reweighting Scenario No Reweighting Standard Weighting under traditional MIPS Reweight 1 Performance Category No Cost (Cost Quality and Promoting Interoperability) Quality Category Weight Cost Category Weight Improvement Activities Category Weight Promoting Interoperability Category Weight 30% 30% 15% 25% 55% 0% 15% 30% No Improvement Activities (Improvement Activities Quality) 45% 30% 0% 25% No Promoting Interoperability (Promoting Interoperability Quality) 55% 30% 15% 0% No Quality (Quality Promoting Interoperability) 0% 30% 15% 55% *Table continues on next slide. Note: Small practices have a different distributio n policy than individual clinicians, larger groups, and virtual groups. 36 Appendix Appendix B. MIPS Performance Category Weight Redistribution Policies Under Traditional MIPS Finalized for the 2022 Performance Year: Individual Clinicians, Groups and Virtual Groups (continued) MIPS Performance Category Reweighting Scenario Reweight 2 Performance Categories No Cost + No Promoting Interoperability (Cost + Promoting Interoperability Quality) No Cost + No Quality (Cost + Quality Promoting Interoperability) No Cost + No Improvement Activities (Cost + Improvement Activities Promoting Interoperability + Quality) No Promoting Interoperability + No Quality (Promoting Interoperability + Quality Cost + Improvement Activities) Quality Category Weight Cost Category Weight Improvement Activities Category Weight 85% 0% 15% 0% 0% 0% 15% 85% 70% 0% 0% 30% 0% 50% 50% 0% Promoting Interoperability Category Weight No Promoting Interoperability + No Improvement Activities 70%reweighted to 30% 0% is (Promoting Interoperability Note: If you have multiple+ performance categories 0% so that a single0% performance category Improvement Activities Quality) weighted at 100% of your final score, you will receive a score equal to the performance threshold regardless of any data submitted or not submitted. See next slide for additional information. No Quality + No Improvement Activities (Quality + Improvement Activities Promoting Interoperability) 0% 30% *Table continues70% on next 0% slide. 37 Appendix Appendix B. MIPS Performance Category Weight Redistribution Policies Under Traditional MIPS Finalized for the 2022 Performance Year: Individual Clinicians, Groups and Virtual Groups (continued) MIPS Performance Category Reweighting Scenario Quality Category Weight Cost Category Weight Improvement Activities Category Weight Promoting Interoperability Category Weight Reweight 3 Performance Categories If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you will receive a score equal to the performance threshold regardless of any data submitted or not and receive a neutral payment adjustment. Reweight 4 Performance Categories If all performance categories are reweighted to 0%, you will receive a score equal to the performance threshold regardless of any data submitted or not and receive a neutral payment adjustment. 38 Appendix Appendix C. MIPS Performance Category Weight Redistribution Policies for APM Entities and the APP Finalized for the 2022 Performance Year The table below illustrates the 2022 performance category weights and reweighting policies that apply to APM Entities reporting traditional MIPS, and to individual clinicians, groups and APM Entities reporting the APP. Reminders: • Cost is not scored under the APP. • There are no reporting requirements for the improvement activities performance category under the APP for the 2022 performance year. Participants reporting via the APP will automatically receive full credit for the improvement activities performance category for performance year 2022. • Participants reporting via the APP will follow the same reporting requirements as traditional MIPS for the Promoting Interoperability performance category. MIPS Performance Category Reweighting Scenario under the APP No Reweighting Standard Weighting under the APP Quality Category Weight Cost Category Weight Improvement Activities Category Weight 50% 0% 20% 30% 75% 0% 25% 0% 0% 0% 25% 75% Promoting Interoperability Category Weight Reweight 1 Performance Category No Promoting Interoperability (Promoting Interoperability Quality) No Quality (Quality Promoting Interoperability) Reweight 2 + Performance Categories If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you will receive a score equal to the performance threshold regardless of any data submitted or not and receive a neutral payment adjustment. 39 Appendix Appendix D. MIPS Promoting Interoperability Hardship Exception Application Status Descriptions The table below provides a description of each application status in the order of which they occur. Draft in Progress Submitted – Pending Approval Approved / Denied Withdrawn You are currently working on your application and haven’t submitted it application yet. You have successfully completed and submitted your application. We completed our review of your application and approved your request. You have withdrawn your application. You can withdraw your application at any point in the process. Select Manage to continue working on your application. Applications are reviewed in the order of which they are received. We completed our review of your application and denied your request. An application can’t be re-opened after being withdrawn. You’ll need to complete a new application. 40