To participate in MIPS, clinicians and groups must possess certified electronic health record technology (CEHRT) to participate in the advancing care information performance category of the program.
Under the Merit-based Incentive Payment System (MIPS) scoring, MIPS-eligible clinicians and groups may qualify for a re-weighting of their score in the category to 0 percent, if they meet certain criteria.
A MIPS-eligible clinician or 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
Some MIPS-eligible clinicians (Special Status) will be automatically re-weighted (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
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Non-patient facing clinicians
In 2018, CMS is proposing to provide more MIPS exemptions including raising clinician’s financial ceiling of earnings from Medicare patients to $90,000 and doubling the Medicare patient load to 200.
The Quality Payment Program Hardship Exception Application for the 2017 transition year opened August 2, 2017. Start here for information and how to apply.
MIPS defines four categories of eligible clinician performance, contributing to an annual MIPS final score of up to 100 points.
2017 Four Categories of Performance = Annual MIPS score (up to 100 points)
Advancing Care Information 25%
Improvement Activities (IA) 15%