Certified electronic health record technology (CEHRT) is required for participation in the advancing care information performance category of the Quality Payment Program (QPP) created by MACRA. The QPP has two paths for participation: Merit-based Incentive Payment System (MIPS) and Advance Alternative Payment Models (AAPMs).
Most clinicians are covered under MIPS. If you are a MIPS-eligible clinician, you and your group may qualify for a reweighting of your advancing care information performance category score to 0 percent of your final score if you meet the criteria outlined below and you file for a hardship exception – very commonly used in nephrology.
You or your group may submit a Quality Payment Program Hardship Exception Application, citing one of the following specified reasons for review and approval:
Insufficient Internet Connectivity
Extreme and Uncontrollable Circumstances
Lack of Control over the availability of CEHRT
The 25 percent weighting of the advancing care information performance category would be reallocated to the quality performance category. Simply lacking CEHRT does not qualify you or your group for reweighting.
Special Status Clinicians
There are some MIPS-eligible clinicians that are considered Special Status, who will be automatically reweighted (or exempted in the case of MIPS-eligible clinicians participating in a MIPS APM) and do not need to submit a Quality Payment Program Hardship Exception Application.
For 2017 Special Status clinicians include the following:
Hospital-based MIPS-eligible clinicians
Clinical nurse specialists
Certified registered nurse anesthetists
The Quality Payment Program Hardship Exception Application
The Quality Payment Program Hardship Exception Application for the 2017 transition year opened August 2, 2017. You may complete the application online or you may also contact the Quality Payment Program Service Center and work with a representative to verbally submit an application. Applications are subject to annual renewal.
To streamline the process, the application is available to both individual clinicians and groups.
To submit your application, you’ll need:
Your Taxpayer Identification Number (TIN) or National Provider Identifier (NPI)
- NPI for Individual Applications
- TIN for Group Applications
Contact information from person working on behalf of the individual clinician or group:
- Submitter First Name
- Submitter Last Name
- Submitter Email Address (This is how we will communicate with you.)
- Submitter Business Telephone Number (Include area code)
- Submitter Extension
Select the hardship exception category and supplemental information:
- Insufficient Internet Connectivity
- Extreme and Uncontrollable Circumstances
- Lack of Control over the Availability of CEHRT
If you are applying for a hardship exception based on Extreme and Uncontrollable Circumstance category, you must select one of the following and provide a start and end date of when the circumstance occurred.
- Disaster (i.e. a natural disaster in which the CEHRT was damaged or destroyed)
- Practice or Hospital Closure
- Severe Financial Distress (Bankruptcy or debt restructuring)
- EHR Certification/Vendor Issues (CEHRT issues)
- If your product was decertified, you must provide the Certification Number
Once the application is submitted, you will receive a confirmation email that your application was submitted and is in a pending, approved, or dismissed status. Applications will be processed on a rolling basis.