Tag Archives: Quality Payment Program

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Quality Payment Program 2020 Updates and Requirements (Part I)

Category:Articles Authored by Apollo HIT Staff,Quality Payment Program in 2020,Quality Payment Program Information Tags : 

Posted February 5, 2020

The Journal of the American Health Information Management Association (JAHIMA) published an article titled Quality Payment Program: 2020 Changes and Requirements Part 1, the first of a five-part series on the Quality Payment Program for 2020.  The article was authored by Michael Stearns, MD, CPC, CRC, CFPC, founder and CEO of Apollo HIT, LLC. Dr. Stearns has served as a principal author for JAHIMA on articles related to the QPP.

Part I of this series provides background on the MIPS and quick reference tables that identify key requirements for 2020, contrasted with the requirements for 2019.


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The Small Practice Promoting Interoperability Hardship Exception – Use Caution

Category:Quality Payment Program Information Tags : 

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.

Please contact us at info@apollohit.com for questions or support.