The Quality Payment Program (QPP) offers several MIPS Exception Applications to help clinicians manage unpredictable challenges that can affect their performance and participation in MIPS. These exceptions allow eligible clinicians to request a reweighting or exemption from certain performance categories. Below is an overview of the key exceptions, their deadlines, and why an eligible clinician might apply for them.

Types of MIPS Exception Applications

1. Extreme and Uncontrollable Circumstances Exception

• This exception is designed for clinicians, groups, or virtual groups impacted by unforeseen and unavoidable circumstances. These can include natural disasters, pandemics, public health emergencies, or systemic issues with IT systems. The aim is to offer relief when external factors make it impossible to meet the MIPS requirements.
• Key features: If granted, one or more of the MIPS performance categories — Quality, Cost, Improvement Activities, or Promoting Interoperability — may be reweighted to 0%, and the other categories will carry more weight in determining the final score.
• 2024 Deadline: The deadline for this application is December 31, 2024, for the 2024 performance year. Clinicians who experience extreme circumstances late in the year can still apply after the event but must meet this deadline.

Please note that Alternative Payment Models (APM) Entities can apply for the Extreme and Uncontrollable Circumstances exception, but will be required to apply for all performance categories.

2. Promoting Interoperability (PI) Hardship Exception

• This exception is for clinicians or groups facing issues specific to the Promoting Interoperability category, such as lack of internet access, difficulties with their electronic health record (EHR) system, or small practices that may not have the resources to meet the requirements.
• Key features: If approved, the PI category will be reweighted to 0%, with the other categories receiving higher weights. This ensures that clinicians aren't unfairly penalized due to technical barriers.
• 2024 Deadline: The deadline for the PI Hardship Exception is December 31, 2024, aligning with the Extreme and Uncontrollable Circumstances Exception.

Why Apply for an Exception?

MIPS performance affects future Medicare payments, and failing to meet the required benchmarks could lead to negative payment adjustments. Exception applications protect clinicians by offering flexibility when external or internal challenges arise, such as:

• Natural Disasters: In regions affected by hurricanes, floods, or other disasters, practices may be unable to perform regular operations, including reporting on MIPS requirements.
• Public Health Emergencies: Events like the COVID-19 pandemic drastically altered how healthcare providers could offer services. Clinicians impacted by similar events can apply for exceptions to avoid penalties.

*It’s important to recognize that the COVID-19 public health emergency concluded on May 11, 2023 and CMS is no longer accepting EUC applications relating to COVID-19 for the 2024 performance year.

• Cyber Attacks: If you were impacted by the Change Healthcare cyber attack or any other cyber attack, you may be eligible.
• Technological Barriers: Small or rural practices that lack the resources for full electronic health record implementation or sufficient internet access often struggle with the Promoting Interoperability category. This hardship exception prevents those clinicians from receiving negative payment adjustments due to issues beyond their control.
• Practice-specific Challenges: In smaller practices or areas with resource constraints, completing certain MIPS categories might be disproportionately burdensome. These exceptions provide a path to fair evaluation.

Deadlines and Submission

The deadline for both the Extreme and Uncontrollable Circumstances Exception and the PI Hardship Exception for the 2024 performance year is December 31, 2024 at 8 p.m. ET. Early submission is encouraged, especially if you are already aware of circumstances that could impact your ability to comply with MIPS requirements.

By staying informed and submitting an exception application when necessary, you can avoid penalties and maintain your MIPS participation standing. At Quantician, we understand how challenging understanding the intricacies of MIPS can be. We guide you through the process, help identify if an exception is appropriate for your situation, and ensure you submit your application before the relevant deadlines.

For more information, visit QPP Exception Applications.