Appendix H1 2024 MIPS Promoting Interoperability Hardship Exception

Quality Payment Program (QPP)/Merit-Based Incentive Payment System (MIPS) (CMS-10621)

Appendix H1 2024 MIPS Promoting Interoperability Hardship Exception Application Guide

OMB: 0938-1314

Document [pdf]
Download: pdf | pdf
Merit-based
Incentive
Payment System
(MIPS)
2024 MIPS Promoting Interoperability
Performance Category Hardship
Exception Application Guide

Table of Contents
How To Use This Guide

3

MIPS Promoting Interoperability Performance Category Hardship
Exception Application Overview

5

MIPS Promoting Interoperability Performance Category Hardship
Exception Information

7

MIPS Promoting Interoperability Performance Category Hardship
Exception: Frequently Asked Questions

12

MIPS Promoting Interoperability Performance Category Hardship
Exception: Application Steps

14

Help and Version History

30

Appendices

33

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.

Already know what MIPS is? Skip
ahead by clicking the links in the Table
of Contents.

2

How to Use This
Guide

3

OVERVIEW

How to Use This Guide

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.

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.
Hyperlinks
Hyperlinks to the Quality Payment Program
website are included throughout the guide to
direct the reader to more information and
resources.

4

MIPS Promoting
Interoperability
Performance Category
Hardship Exception
Application Overview

5

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION APPLICATION OVERVIEW

Overview
What

MIPS Promoting Interoperability Hardship Exception applications allow you to request that your MIPS Promoting Interoperability
performance category be reweighted to 0%.

Who

Individual clinicians, groups, and virtual groups reporting via traditional MIPS, MIPS Value Pathways (MVPs) or the Alternative Payment
Model (APM) Performance Pathway (APP).
• Third party intermediaries can submit an application with permission from the clinician or practice.
• APM Entities can’t submit an application at the APM Entity level.
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.

Note: We automatically

Why

When
Where

How

reweight Promoting
You can submit an application to have your MIPS Promoting Interoperability performance category reweighted to 0% if:
Interoperability for
• You have insufficient Internet connectivity.
small practices. See
• You have decertified electronic health record (EHR) technology (decertified under the Office of the National
page 8 for more
Coordinator for Health Information Technology's (ONC) Health IT Certification Program).
information.
• You lack control over the availability of certified EHR technology (CEHRT).
o Simply lacking CEHRT functionality that meets ONC’s certification criteria in 45 CFR 170.315 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.

The Promoting Interoperability Hardship Exception application will close at 8 p.m. ET on December 31, 2024.
Sign in to the Quality Payment Program (QPP) website 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,
3MB).
1. Register for a HARP account.
2. Sign in to the QPP website.
3. Select ‘Exceptions Application’ on the left-hand navigation.

4. Select ‘Add New Exception.’
5. Select ‘Promoting Interoperability Hardship Exception.’
6. Complete the application for individual, group, or virtual group
participation.

See Appendix B (traditional MIPS) and Appendix C (APP) for more information on performance category reweighting.

6

MIPS Promoting
Interoperability
Performance Category
Hardship Exception
Information

7

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION INFORMATION

Overview
You may automatically qualify for reweighting in this performance category.
• See Appendix A.
• If you automatically quality for reweighting, you don’t need to submit a Hardship Exception application.
You’ll complete the Hardship Exception application at the level for which you’ll report data to MIPS for other performance categories.
• If you’re reporting data at the individual level, complete the Hardship Exception application at the individual level.
• If you’re 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.
o If clinicians in your practice participate in MIPS at the individual level, don’t complete the Hardship Exception application at the group
level. You’ll complete the Hardship Exception application at the individual level for each clinician (who doesn’t automatically qualify for
reweighting) to be considered for reweighting.
o If you’re reporting an MVP as a subgroup, an approved group level Hardship Exception will apply to the subgroup participants.
Did You Know? Subgroups can’t submit a Promoting Interoperability Hardship Exception application at the subgroup level but a
subgroup will inherit any reweighting approved for their affiliated group.

You can still submit data for the MIPS Promoting Interoperability performance category.
• If your circumstances change and you’re able to collect and submit Promoting Interoperability data, we’ll disregard your Hardship
Exception application and you’ll be scored in this performance category.
• You’ll 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. The submission of data cancels a hardship exception and automatic reweighting

Reminder: Small practices qualify for automatic reweighting of the Promoting Interoperability performance category.

8

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION INFORMATION

Overview (Continued)
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’re selected by CMS for data validation or audit. See our 2024 MIPS Data Validation
Criteria (ZIP, 2MB) for details on the data validation process.
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 EHR product is decertified under ONC’s Health IT Certification Program during the 2024
performance year.
• You can 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

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
exception 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 exception and
must report for those clinicians for whom they have data.

10

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION INFORMATION

MIPS APM Participants
MIPS eligible clinicians and groups participating in a MIPS APM can apply for hardship exceptions and qualify for automatic
reweighting.
If you’re participating in MIPS at the APM Entity level (either reporting traditional MIPS or the APP), you can complete the
application as an individual or group.
• If approved, the MIPS eligible 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 APM Entity.
• MIPS eligible clinicians in the APM Entity would need to submit the MIPS Promoting Interoperability Performance Category
Hardship Exception application at the individual or group level, as appropriate to their circumstances.
A MIPS Promoting Interoperability performance category hardship exception doesn’t exempt you from reporting on any CEHRT
activities as may be required by your APM.

Reminder: The Promoting Interoperability Performance Category Hardship Exception application isn’t available
to APM Entities.

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 My MIPS Promoting
Interoperability Performance Category Hardship Exception
Application?

Answer

You can monitor your application status in your QPP Account on
the QPP website.
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 In the Additional Access section of the application, provide the
email address(es) of additional staff or representatives who you
the Status of the MIPS Promoting Interoperability Performance
would like to receive email notifications.
Category Hardship Exception Application?

How Can I Correct a Mistake Made on Our MIPS Promoting
Interoperability Performance Category Hardship Exception
Application?

Please note: the additional staff or representatives must have
HARP credentials to see the application on the QPP website.
If you identify an error with your application, please contact the
Quality Payment Program Service Center by email at
[email protected], by creating a QPP Service Center ticket, or
by phone at 1-866-288-8292 (Monday-Friday,
8 a.m. - 8 p.m. ET).

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
With your HARP credentials, sign in to your QPP Account on the QPP
website.

Note: If you haven’t signed in on the QPP website before, you must
register for an account to obtain your HARP credentials. See our QPP
Account Access Guide (ZIP, 3MB) 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 the experience, there may be differences
between these screenshots and what you see on the QPP website.

15

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 2: Navigate to Your Exception Applications
Once you’re 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
December 31, 2024.

*The screenshots included
in this user guide were
based on the QPP test
environment. Because we
are always working to
incorporate feedback and
improve the experience,
there may be differences
between these
screenshots and what you
see on the QPP website.

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 click 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 the experience, there may be differences
between these screenshots and what you see on the QPP website.

17

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 4: Select Application Type
Select the participation level at which you intend (or intended) to
participate in MIPS, then select Save & 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 the experience, there may be differences
between these screenshots and what you see on the QPP website.

(Image features application at the individual level)

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 Level
Individual Clinician

Group
Virtual Group

Required Information
• National Provider Identifier
(NPI)
• Practice Affiliation
• Taxpayer Identification
Number (TIN)
• Virtual Group Identifier

*The screenshots included in this user guide were
based on the QPP test environment. Because we
are always working to incorporate feedback and
improve the experience, there may be differences
between these screenshots and what you see on
the QPP website.

(Image features application at the individual level)

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 the experience, there may be differences
between these screenshots and what you see on
the QPP website.

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 the QPP website 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 the experience, there may be differences
between these screenshots and what you see on
the QPP website.

21

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 8: Select the Reason for the MIPS Promoting Interoperability
Hardship
Select the option that aligns with your reason for submitting a 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
2024 MIPS Data Validation Criteria (ZIP,
2MB) 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 the experience, there may be
differences between these screenshots
and what you see on the QPP website.

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.

*The screenshots included in this user guide
were based on the QPP test environment.
Because we are always working to
incorporate feedback and improve the
experience, there may be differences
between these screenshots and what you see
on the QPP website.

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 the experience, there may
be differences between these screenshots and what you see on
the QPP website.

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 circumstances event
type that applies to you, enter the 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 the experience, there
may be differences between these screenshots and what
you see on the QPP website.

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 the
experience, there may be differences between these
screenshots and what you see on the QPP website.

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 (under
ONC’s Health IT Certification Program) and your ONCACB 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 the
experience, there may be differences between these
screenshots and what you see on the QPP website.

27

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 10: Submit MIPS Promoting Interoperability Hardship
Exception Application
Once you’re 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 the
experience, there may be differences between these
screenshots and what you see on the QPP website.

28

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

MIPS Promoting Interoperability Hardship Exception Application
Submission Confirmation
After you submit your MIPS Promoting Interoperability
Hardship Exception application, you’ll receive a message
stating that your Hardship Exception application has
been successfully submitted and is pending review.

You’ll 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 the
experience, there may be differences between these
screenshots and what you see on the QPP website.

29

Help and Version
History
30

HELP AND VERSION HISTORY

Where Can You Go for Help?

Contact the Quality Payment
Program Service Center by email at
[email protected], by creating a
QPP Service Center ticket, or by
phone at 1-866-288-8292 (Monday
through Friday,
8 a.m. - 8 p.m. ET). People who are
deaf or hard of hearing 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 Resource Library.

31

HELP AND VERSION HISTORY

Version History
If we need to update this document, changes will be identified here.

D AT E

DESCRIPTION

06/25/2024

Updated to include PRA disclosure language.

05/13/2024

Original Posting.

According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it
displays a valid OMB control number. The valid OMB control number for this information collection is 0938-1314 (Expiration date:
01/31/2025). The time required to complete this information collection is estimated to average .25 hours per response, including
the time to review instructions, search existing data resources, gather the data needed, and complete and review the information
collection. If you have comments concerning the accuracy of the time estimate(s) or suggestions for improving this form, please
write to: CMS, 7500 Security Boulevard, Attn: PRA Reports Clearance Officer, Mail Stop C4-26-05, Baltimore, Maryland 212441850. ****CMS Disclosure**** Please do not send applications, claims, payments, medical records or any documents containing
sensitive information to the PRA Reports Clearance Office. Please note that any correspondence not pertaining to the information
collection burden approved under the associated OMB control number listed on this form will not be reviewed, forwarded, or
retained. If you have questions or concerns regarding where to submit your documents, please contact QPP at [email protected].

32

Appendices

33

APPENDICES

Appendix A. Automatic Reweighting in the MIPS Promoting
Interoperability Performance Category
Reason for Reweighting (Individual Clinicians)
You're the following clinician type or have one of these Special
Statuses:
• Clinical Social Worker
• Small Practice;
• Ambulatory Surgical Center (ASC)-based;
• Hospital-based; or
• Non-patient facing
Reason for Reweighting (Groups and Virtual Groups)

Action Needed by the Individual
None – You’re automatically excepted from having to submit data
for this performance category as an individual, though you may still
choose to do so.

You’ll be scored in this performance category if your practice is
participating as a group or virtual group and doesn’t qualify for
reweighting.
Action Needed by the Group or Virtual Group

You have one of these Special Statuses:
• ASC-based.
• Small Practice
• Hospital-based: Group or virtual group must have more than
75% of clinicians designated as hospital-based.
• Non-patient facing: Group or virtual group must have more
than 75% of clinicians designated as non-patient facing.

You’ll be scored in this performance category if your practice is
participating as a group or virtual group and doesn’t qualify for
reweighting.

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 approved hardship exceptions).

You’ll be scored in this performance category if your practice is
participating as a group or virtual group and doesn’t qualify for
reweighting.

34

APPENDICES

Appendix B. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS and MVPs Finalized for the 2024 Performance
Year: Individual Clinicians, Groups, and Virtual Groups
The table below illustrates the 2024 performance category weights and reweighting policies that CMS will
apply to clinicians, groups, and virtual groups reporting via traditional MIPS or MVPs.

Refer to Appendix D for reweighting
policies that apply to APM Entities.

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
2026 payment year.
MIPS Performance Category Reweighting
Scenario

Quality Category
Weight

Cost Category Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

30%

30%

15%

25%

No Cost
(Cost → Quality and Promoting
Interoperability)

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%

No Reweighting
Standard Weighting under traditional MIPS
Reweight 1 Performance Category

Note: Small practices have a different performance category weight distribution
policy than individual clinicians, larger groups, and virtual groups.

*Table continues on next slide.

35

APPENDICES

Appendix B. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS and MVPs Finalized for the 2024 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

85%

0%

15%

0%

0%

0%

15%

85%

70%

0%

0%

30%

0%

50%

50%

0%

70%

30%

0%

0%

0%

30%

0%

70%

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)
No Promoting Interoperability + No
Improvement Activities
(Promoting Interoperability +
Improvement Activities → Quality)
No Quality + No Improvement Activities
(Quality + Improvement Activities →
Promoting Interoperability)

Note: If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final
score, you’ll receive a score equal to the performance threshold regardless of any data submitted. See next slide for additional information.

*Table continues on next slide.

36

APPENDICES

Appendix B. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS and MVPs Finalized for the 2024 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’ll
receive a score equal to the performance threshold regardless of any data submitted and you’ll receive a neutral payment adjustment.
Reweight 4 Performance Categories
If all performance categories are reweighted to 0%, you’ll receive a score equal to the performance threshold regardless of any data submitted and
you’ll receive a neutral payment adjustment.

37

APPENDICES

Appendix C. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS Finalized for the 2024 Performance Year: Small
Practices
The table below illustrates the 2024 performance category weights and
reweighting policies that CMS will apply to small practices.

MIPS Performance Category Reweighting
Scenario

Refer to Appendix D for reweighting policies that apply
to APM Entities reporting the APP. APM Entities
reporting traditional MIPS or MVPs can only request
reweighting for all performance categories.

Quality Category
Weight

Cost Category Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

30%

30%

15%

25%

No Cost
(Cost → Quality and Promoting
Interoperability)

55%

0%

15%

30%

No Improvement Activities
(Improvement Activities → Quality)

45%

30%

0%

25%

No Promoting Interoperability
(Promoting Interoperability → Quality
and Improvement Activities)

40%

30%

30%

0%

No Quality
(Quality → Promoting Interoperability)

0%

30%

15%

55%

No Reweighting
Standard Weighting under traditional MIPS
Reweight 1 Performance Category

*Table continues on next slide.

38

APPENDICES

Appendix C. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS Finalized for the 2024 Performance Year: Small
Practices
MIPS Performance Category Reweighting
Scenario

Quality Category
Weight

Cost Category Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

50%

0%

50%

0%

0%

0%

15%

85%

70%

0%

0%

30%

0%

50%

50%

0%

70%

30%

0%

0%

0%

30%

0%

70%

Reweight 2 Performance Categories
No Cost + No Promoting Interoperability
(Cost + Promoting Interoperability →
Quality and Improvement Activities)
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)
No Promoting Interoperability + No
Improvement Activities
(Promoting Interoperability +
Improvement Activities → Quality)
No Quality + No Improvement Activities
(Quality + Improvement Activities →
Promoting Interoperability)

Note: If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score,
you’ll receive a score equal to the performance threshold regardless of any data submitted and you’ll receive a neutral payment adjustment.

39

APPENDICES

Appendix D. MIPS Performance Category Weight Redistribution
Policies for APM Entities and the APP Finalized for the 2024
Performance Year
The table below illustrates the 2024 performance category weights and reweighting policies that apply to individual clinicians, groups, and
APM Entities reporting via the APP.
Reminders:
• The cost performance category weight is zero percent for clinicians scored through the APP.
• There are no reporting requirements for the improvement activities performance category under the APP for the 2024 performance
year. Participants reporting via the APP will automatically receive full credit for the improvement activities performance category for
the 2024 performance year.
• MIPS participants reporting via the APP will follow the same reporting requirements as traditional MIPS for the Promoting
Interoperability performance category.
Quality Category
Cost Category
MIPS Performance Category Reweighting Scenario
Improvement Activities
Promoting Interoperability
Weight
Weight
under the APP
Category Weight
Category Weight
No Reweighting

Standard Weighting under the APP

50%

0%

20%

30%

75%

0%

25%

0%

0%

0%

25%

75%

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’ll
receive a score equal to the performance threshold regardless of any data submitted and you’ll receive a neutral payment adjustment.
40

APPENDICES

Appendix E. 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

We completed our review of your
application and approved your
request.
You’re currently working on your
application and haven’t
submitted it yet.
Select Manage to continue
working on your application.

You’ve successfully completed
and submitted your application.
Applications are reviewed in the
order of which they’re received.
We completed our review of your
application and denied your
request.

Withdrawn

You’ve withdrawn your
application. You can withdraw
your application at any point in
the process.
An application can’t be reopened
after being withdrawn. You’ll
need to complete a new
application.

41


File Typeapplication/pdf
File TitleMerit-based Incentive Payment System (MIPS): 2024 MIPS Promoting Interoperability Performance Category Hardship Exception Applic
SubjectMerit-based Incentive Payment System (MIPS): 2024 MIPS Promoting Interoperability Performance Category Hardship Exception Applic
AuthorHHS/CMS
File Modified2024-06-22
File Created2024-06-18

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