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Industry Insights

CMS Accepting 2022 MIPS Exception Applications
CMS has announced it is now accepting Merit-based Incentive Payment System (MIPS) Exception applications for clinicians and groups who have been impacted by extreme or uncontrollable circumstances in 2022 and would like to opt-out of the current reporting year. Similar to the past two years, CMS is allowing groups impacted by the COVID-19 Public Health Emergency to request the reweighting of all or some of their performance categories. Groups who request and are approved for a full exception will not be required to submit reporting data and will receive a neutral (0%) Medicare adjustment in the 2024 payment year. Applications are due by 8 p.m., ET, Dec. 31, 2022. Other qualifying events are described by CMS as those that:
  • Cause you to be unable to collect information necessary to submit for a MIPS performance category.
  • Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for 3 months), and/or;
  • Impact your normal process, affecting your performance on cost measures and other administrative claims measures.
Below are additional notes from CMS on how to apply for the exception and when you’ll be notified if approved: How do I apply? You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself, or another MIPS eligible clinician, group, virtual group or APM Entity. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide. Once you register for a HARP account, sign in to the QPP website, select ‘Exceptions Applications’ on the left-hand navigation, select ‘Add New Exception,’ and select ‘Extreme and Uncontrollable Circumstances Exception’ or ‘Promoting Interoperability Hardship Exception.’ How do I know if I’m approved? You’ll be notified by email if your request was approved or denied.  You can also check the status of your application by signing into the QPP website and navigating to Exceptions. If approved, this information will also be added to your eligibility profile in the QPP Participation Status Tool on a rolling basis. If your application is approved at the end of the performance year, it may not appear in the QPP Participation Status Tool until the submission window is open in 2023. If you need assistance with this process, or have questions about whether an opt-out is beneficial for your group, don’t hesitate to contact us for a free consultation.  

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