CMS will allow clinicians to choose from a number of hardship exceptions for the Promoting Interoperability performance category of MIPS.  On the 2019 MIPS Promoting Interoperability Fact Sheet has as one of the choices, “You are in a small practice.”  The application process has similar language, simply asking clinicians to attest to being in a small practice in order to receive the exception.

This can be misleading.  CMS published a 2019 MIPS Exceptions FAQs that includes additional information on the small practice hardship exception.   The following is abstracted from that document:

Question: Are there Promoting Interoperability performance category hardship exceptions for clinicians in a small practice?

CMS Response: Yes. We recognize that adopting and implementing CEHRT may be a significant hardship for some, but not all, small practices. For small practices experiencing a significant hardship, you can apply for a hardship exception by selecting small practice if there are overwhelming barriers to complying with the requirements of the Promoting Interoperability performance category. You do not need to submit documentation of the overwhelming barriers with your application, but please retain this documentation in the event of an audit.


  1. If you feel your small practice has experienced overwhelming (administrative, financial or other) barriers to meeting the requirements of the Promoting Interoperability performance category, and no other hardship exceptions are more applicable, consider submitting a hardship exception for the PI category of MIPS.
  2. Create and securely store detailed information as to why your practice faced “overwhelming barriers” to participation in the PI category.  An audit may occur years from now, but the auditors will look back into prior performance years.

If you have already submitted the small practice hardship exception but feel that you may not have sufficient justification to claim the exception, you still have the option of reporting Promoting Interoperability data for 2019. If you elect to do so the hardship exception will be essentially cancelled.

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