Appendix H 2024 MIPS Promoting Interoperability Hardship Exception

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.

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How to Use This Guide

 

How to Use This Guide

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MIPS Promoting Interoperability Performance Category Hardship Exception Application Overview

 

Overview

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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.  

• oIf 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.  

• oIf you’re reporting an MVP as a subgroup, an approved group level Hardship Exception will apply to the subgroup participants. 

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 

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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.  

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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. 

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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.

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MIPS Promoting Interoperability Performance Category Hardship Exception: Frequently Asked Questions

 

Question	Answer
Where Can I Look for a Status Update on My MIPS Promoting Interoperability Performance Category Hardship Exception Application?	You can monitor your application status in your QPP Account on the QPP website.
Can Additional Staff Members Access/Receive Notifications About the Status of the MIPS Promoting Interoperability Performance Category Hardship Exception Application?	Yes, you can add additional staff or representatives who should receive notifications about the status of the application. In the Additional Access section of the application, provide the email address(es) of additional staff or representatives who you would like to receive email notifications. Please note: the additional staff or representatives must have HARP credentials to see the application on the QPP website.
How Can I Correct a Mistake Made on Our MIPS Promoting Interoperability Performance Category Hardship Exception Application?	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).

 

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.

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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.  

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Step 3: Select the Exception Application

Select the MIPS Promoting Interoperability Performance
Category Hardship Exception, then click Continue.

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Step 4: Select Application Type

Select the participation level at which you intend (or intended) to participate in MIPS, then select Save & Continue.

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Step 5: Enter Participation Level Information

Enter the required participation level information.

The required information for each participation level is as follows:

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Step 6: Enter Submitter Details

Enter your contact information (as the submitter) and identify your relationship to the party identified in the application.

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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.

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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.

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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.

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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.

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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.

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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.

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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 ONC-ACB Certification ID. Then, review the attestation statement and select “I attest.”

You can provide an optional description of the hardship event.

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Step 10: Submit MIPS Promoting Interoperability Hardship Exception Application

Once you’re done with your application, review the disclosures, then select Certify & Submit.

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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.

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Help and Version History

 

 

Version History

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

DATE	DESCRIPTION
08/30/2024	Added OMB control number and expiration date on slide 1 and updated PRA disclosure language on slide 32.
06/25/2024	Updated to include PRA disclosure language.
05/13/2024	Original Posting.

 

Appendices

 

Appendix A. Automatic Reweighting in the MIPS Promoting Interoperability Performance Category

Reason for Reweighting (Individual Clinicians)	Action Needed by the Individual
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	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.
Reason for Reweighting (Groups and Virtual Groups)	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.

 

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 

MIPS Performance Category Reweighting Scenario	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
No Reweighting
Standard Weighting under traditional MIPS	30%	30%	15%	25%
Reweight 1 Performance Category
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%

 

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 2 Performance Categories
No Cost + No Promoting Interoperability (Cost + Promoting Interoperability  Quality)	85%	0%	15%	0%
No Cost + No Quality (Cost + Quality  Promoting Interoperability)	0%	0%	15%	85%
No Cost + No Improvement Activities (Cost + Improvement Activities  Promoting Interoperability + Quality)	70%	0%	0%	30%
No Promoting Interoperability + No Quality (Promoting Interoperability + Quality  Cost + Improvement Activities)	0%	50%	50%	0%
No Promoting Interoperability + No Improvement Activities (Promoting Interoperability + Improvement Activities  Quality)	70%	30%	0%	0%
No Quality + No Improvement Activities (Quality + Improvement Activities  Promoting Interoperability)	0%	30%	0%	70%

 

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.

 

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
No Reweighting
Standard Weighting under traditional MIPS	30%	30%	15%	25%
Reweight 1 Performance Category
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%

 

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
Reweight 2 Performance Categories
No Cost + No Promoting Interoperability (Cost + Promoting Interoperability  Quality and Improvement Activities)	50%	0%	50%	0%
No Cost + No Quality (Cost + Quality  Promoting Interoperability)	0%	0%	15%	85%
No Cost + No Improvement Activities (Cost + Improvement Activities  Promoting Interoperability + Quality)	70%	0%	0%	30%
No Promoting Interoperability + No Quality (Promoting Interoperability + Quality  Cost + Improvement Activities)	0%	50%	50%	0%
No Promoting Interoperability + No Improvement Activities (Promoting Interoperability + Improvement Activities  Quality)	70%	30%	0%	0%
No Quality + No Improvement Activities (Quality + Improvement Activities  Promoting Interoperability)	0%	30%	0%	70%

 

Appendix D. MIPS Performance Category Weight Redistribution Policies for APM Entities and the APP Finalized for the 2024 Performance Year 

MIPS Performance Category Reweighting Scenario under the APP	Quality Category Weight	Cost Category Weight	Improvement Activities Category Weight	Promoting Interoperability Category Weight
No Reweighting
Standard Weighting under the APP	50%	0%	20%	30%
Reweight 1 Performance Category
No Promoting Interoperability (Promoting Interoperability  Quality)	75%	0%	25%	0%
No Quality (Quality  Promoting Interoperability)	0%	0%	25%	75%
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.

 

Appendix E. MIPS Promoting Interoperability Hardship Exception Application Status Descriptions

Draft in Progress	Submitted – Pending Approval	Approved / Denied	Withdrawn
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 approved your request.	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.
		We completed our review of your application and denied your request.

 

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