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Promoting Interoperability Hardship Exception December 31 Deadline

Tuesday, December 18, 2018

Certified electronic health record technology (CEHRT) is required for participation in the Promoting Interoperability (formerly Advancing Care Information) performance category of the Quality Payment Program (QPP).

Under Merit-based Incentive Payment System (MIPS) scoring, MIPS-eligible clinicians and groups may qualify for a reweighting of their Promoting Interoperability performance category score to 0 percent of the final score if they meet the criteria. The 25 percent weighting of the Promoting Interoperability performance category would be reallocated to the Quality performance category.

Lacking CEHRT does not qualify the MIPS-eligible clinician or group for reweighting. MIPS-eligible clinicians or groups may submit a Quality Payment Program Exception Application citing one of the following specified reasons for review and approval:

  • MIPS-eligible clinicians in small practices
  • MIPS-eligible clinicians using decertified EHR technology
  • Insufficient Internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of CEHRT

If you are a MIPS-eligible clinician, you must submit an application by December 31, 2018 for CMS to reweight the Promoting Interoperability performance category to 0 percent. The application is available at Visit the CMS Quality Payment Program website ( for additional information including information needed when submitting an application and the list of "Special Status" clinicians who will be automatically reweighted (or exempted).