The Centers for Medicare and Medicaid Services (CMS) has opened the 2022 MIPS hardship applications.
There are two applications available, the Extreme and Uncontrollable Circumstance (EUC) hardship application and the Promoting Interoperability (PI) exception application. Both applications are available in your QPP account.
New for 2022 MIPS: Small practices (<15 clinicians) get automatic PI hardship as long as they do not submit any data for the 2022 PI category.
Factors CMS Considers in Hardship Applications
CMS reviews applications taking into account both the event circumstances (what happened) and the timing (how long the circumstances impacted you) to assess your ability to collect and/or submit data for each performance category selected in the application.
- For the Cost and Quality category exceptions, CMS generally expects the circumstance to have lasted for at least 3 months.
- For example, a natural disaster or ransomware attack that prevented you from collecting Quality data for 3 or more months.
- Because the Improvement Activities (IA) and PI categories have shorter performance periods (only 90 days), CMS expects the circumstances affecting performance or preventing performance in those categories to be more prolonged.
- For example, if you switch EHR vendors during the performance period, you may claim a PI hardship for vendor issues.
Steps to Apply
If you are a MarsdenAdvisors client, contact your Client Success Manager to complete this process for you, otherwise:
- Sign in to your QPP account
- Select "Exception Applications" on the left-hand navigation
- Select "Add New Exception"
- Select either "Promoting Interoperability Hardship Exception" or "Extreme and Uncontrollable Circumstances Exception"
- Complete the application at either the individual, group, virtual group, or APM Entity participation level.
- After you submit your application, you will receive a message and an email stating that your application has been successfully submitted and is pending review.
- Once your application has been reviewed and a decision has been made, CMS will post the decision to your QPP account. You can also monitor your application status from there.
- The deadline to submit hardship applications is December 31, 2022 at 8 pm ET.
- Retain documentation of the hardship for at least six years in case of an audit.
- Hardships from previous years do not carry forward. You must submit a new application each year in which you experience a hardship.
- If you are granted a hardship:
- Do not submit data in the categories for which you received a hardship exception or CMS will score those categories.
- If you submit data on 2+ MIPS categories, CMS will score you on the reported categories and assign you a 2022 MIPS final score and 2024 payment adjustment.
- If you submit data on 1 or fewer MIPS categories (such as small practice claims-based Quality reporters), CMS will assign you a 2022 MIPS score equal to the threshold to avoid a penalty.
- If you get a hardship for all categories, CMS will assign you a score equal to the threshold to avoid a penalty.
- Share this information with your colleagues.
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- If you are a MarsdenAdvisors client
- Contact your Client Success Manager if you have any questions or if you plan on applying for a hardship. Your Client Success Manager will submit the application and retain the necessary documentation on your behalf.
- If you are not a MarsdenAdvisors client
- Contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.
If you have any questions on this, let us know!