Promoting Interoperability Hardship Exceptions

CMS will allow for hardship exceptions for Providing Interoperability (PI) performance category of MIPS. If an exception is granted the 25 MIPS points in the PI performance category will be reallocated to the quality performance category.  This article will summarize information related to hardship exception definitions, as available.

The application process is now open (see link below). To be considered for an exception the practice or a designee must submit the application no later than December 31, 2019.  It may be beneficial to submit hardship exception application as soon as possible. If your application is accepted, you will be notified by email and you will not need to report data from the PI category for 2019. However, you will still have the option of reporting PI data if you elect to do so.  If you submit PI data despite receiving a hardship exception, you will be scored the same as if you did not apply for the exception.

The following list represents examples of reasons specified by CMS as to why a practice may claim an exception for the PI category.  Some of these items have been further defined by information in the application:

  1. Small Group exception: If reporting is a group or as an individual the practice is designated as a small practice and has experienced significant barriers to meeting the PI category requirements. Small practices in MIPS are defined as practices with 15 or fewer eligible clinician types.
  2. Decertified EHR technology exception
  3. Insufficient Internet connectivity
  4. Extreme and uncontrollable circumstances, including but not limited to:
    1. Disasters, natural and otherwise
    2. Practice closure
    3. Severe financial distress
    4. Vendor issues
  5. Lack of availability of Certified EHR Technology

Additional Information on each reason

Small Group Exception:

Updated 8-23-19.  CMS has published guidance on the use of the exception. It is applicable to small practices that experience significant administrative, financial (or potentially other) barriers that prevent them from meeting the requirements of the Promoting Interoperabilty category of MIPS in the 2019 performance year.  For additional information and links to the specific guidance from CMS please see the following article: “MIPS 2019 Promoting Interoperability Small Practice Hardship Exception – Use Caution.”

Decertified EHR Technology Exception:

The application contains the following statement: “In order to be approved for this hardship exception, the clinician(s) must attest to experiencing issues with the certification of the EHR product such as decertification.”

Insufficient Internet Connectivity Exception:

In order to be approved for this hardship exception, the clinician(s) must attest to practicing in an area without sufficient internet access or facing insurmountable barriers to obtaining infrastructure (e.g. lack of broadband).

Extreme and Uncontrollable Circumstances Exception-Disaster

In order to be approved for hardship exception, the clinician(s) must attest to facing Extreme and Uncontrollable Circumstances in the form of a natural disaster in which the EHR system was damaged or destroyed. Practices must attest to the time period the EHR system was unavailable, i.e., (MM/DD/YYYY) to (MM/DD/YYYY).

Extreme and Uncontrollable Circumstances Exception-Severe Financial Distress (Bankruptcy or Debt Restructuring)

Practices must attest attest that the clinician(s) faced extreme and uncontrollable circumstances in the form of severe financial distress resulting in bankruptcy or restructuring of debt.  They must also attest to the time period that the EHR system was unavailable.

Extreme and Uncontrollable Circumstances Exception -Vendor Issues

The practice must attest that the clinician(s) faced extreme and uncontrollable circumstances in the form of vendor issues.  No further specific information is provided, however the user is required to submit the period of time the EHR system was unavailable. Based on this it appears that is only applicable to situations where the EHR system becomes unavailable.

Lack of Control over the Availability of Certified EHR Technology Exception

The practice must attest to a lack of control over the availability of CEHRT in 1 or more practice locations where more than 50 percent of the patient encounters occurred.

In order to apply for an exception further promoting interoperability category of MIPS please go the following website: Promoting Interoperability Hardship Exceptions

Additional information is available on the QPP Exception Application Website

Please contact us at for any questions or feedback on this page or on the Quality Payment Program in general.

CMS will allow for exceptions for all categories of the Quality Payment Program if there is a natural disaster.  In order to qualify, practices may need to go to the QPP website at this address: Extreme and Uncontrollable Circumstances Application

For additional information on meeting the Promoting Interoperability objective please see:

Based on the 2020 Physician Fee Schedule Proposed Rule (that includes changes to the QPP) the general structure of PI will not undergo significant changes for the 2020 performance year.

This website was updated on August 21, 2019. As new information becomes available an attempt will be made to provide to future updates and clarifications.

Disclaimer: the information on this website may contain interpretations of guidance provided by CMS on the above topics. Please review the official documents for specific guidance.

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