The Quality Payment Program (QPP) Hardship Exception Application for the 2017 transition year is now live on the Quality Payment Program website (https://qpp.cms.gov/about/hardship-exception).

Certified electronic health record technology (CEHRT) is required for participation in the Advancing Care Information (ACI) 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 ACI performance category score to 0% of the final score. The 25 percent weighting of the ACI performance category would be reallocated to the quality performance category. Simply lacking CEHRT does not qualify you or your group for reweighting.

A Hardship Exception Application may be submitted for one of the following specified reasons:

• Insufficient Internet Connectivity
• Extreme and Uncontrollable Circumstances
• Lack of Control over the availability of CEHRT

Please note, this hardship exception is for the ACI performance category under MIPS scoring only. It does not exempt you from reporting under the MIPS quality or improvement activities performance categories or from any CEHRT reporting that may be required if you participate in an Alternative Payment Model.

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 the 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.

There are some MIPS eligible clinicians who are considered "special status," who will be automatically reweighted (or, exempted in the case of MIPS eligible clinicians participating in a MIPS Alternative Payment Model) and do not need to submit a QPP Hardship Exception Application.

For more information on the Hardship Exception, as well as the list of "special status clinicians," FAQs, and the online QPP Hardship Exception Application, go to Quality Payment Program website (https://qpp.cms.gov/about/hardship-exception). You may also contact the Quality Payment Service Center at 1-866-288-8292 (TTY: 1-877-715-6222) with your questions or to verbally submit an application.

For general questions on the QPP, you may also contact Stacey Hettiger at (517) 336-5766 or shettiger@msms.org.