New info on QPP participation status, MIPS audits, and hardship exceptions

The Centers for Medicare & Medicaid Services (CMS) has released updated data on Quality Payment Program (QPP) participation status. CMS conducts three “snapshots” per year to determine whether an eligible clinician has attained qualifying participant (QP) status. The latest snapshot analyzed data from Jan. 1 through June 30. The final snapshot, with data from Jan. 1 through Aug. 31, will be released in December.

QPs are exempt from Merit-based Incentive Payment System (MIPS) reporting requirements and eligible for a 3.5% Alternative Payment Model (APM) incentive payment in 2025. You only need to be a QP in one of the three snapshots to qualify. Those considered partial QPs are not required to report to MIPS but may do so voluntarily.

To view your QP status, enter your 10-digit national provider identifier into the QPP Participation Status Tool. The participation tool also includes information on MIPS eligibility, including whether you are required to report as an individual or eligible to report as part of a group.

For additional information on QPP participation, visit the APM Determination Periods and How MIPS Eligibility is Determined webpages.

MIPS audits start soon

CMS will soon begin data validation and audits (DVAs) of MIPS participants for the 2022 performance year. The agency will select practices at random and will send notifications and initial requests for information November 2023 through March 2024.

If CMS selects your practice for a DVA, the security official in your Health Care Quality Information Systems Access, Roles, and Profile (HARP) account will receive an email from CMS’ contractor, Guidehouse (MIPS_DVA_Request@guidehouse.com).

Once notified, you will have 45 days to provide the requested information. Participants who used a third-party vendor to submit MIPS data will be expected to ensure all requested audit documentation is provided to CMS in a complete and timely manner. Failure to comply could result in a payment adjustment and increase the possibility of being selected for a future DVA.

You can find additional information in the MIPS DVA Factsheet for Performance Year 2022. If you have questions pertaining to DVAs, contact Guidehouse at MIPS_DVA@guidehouse.com.

Hardship exemption applications open until Jan. 2

Practices that have experienced extreme hardships and will be unable to report data for the 2023 MIPS performance year have until 8 p.m. ET on Jan. 2, 2024, to apply for an exception. Applications can be submitted on the QPP website.

Practices can request that CMS reweight any or all MIPS performance categories. To qualify for an exception, practices must experience an extreme and uncontrollable circumstance that: 

• Causes you to be unable to collect information necessary to submit for a MIPS performance category;
• Causes you to be unable to submit information that would be used to score a MIPS performance category for an extended period (for example, if you were unable to collect data for the quality performance category for three months); and/or
• Impacts your normal process, affecting your performance on cost measures and other administrative claims measures.

CMS continues to allow practices to request reweighting due to hardships caused by the COVID-19 pandemic.

Practices may also apply for a hardship exception to have the MIPS promoting interoperability category reweighted to 0%. To qualify for the hardship exception, the practice must:

• Have decertified electronic health record (EHR) technology;
• Have insufficient Internet connectivity;
• Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues; or
• Lack control over the availability of certified EHR technology (CEHRT). Simply lacking the required CEHRT doesn’t qualify you for reweighting.

Those who qualify for automatic reweighting of the promoting interoperability performance category do not need to apply.

Learn more by reviewing the 2023 EUC Exception Application Guide and the 2023 MIPS Promoting Interoperability Performance Category Hardship Exception Application Guide.

— Erin Solis, AAFP Manager, Practice & Payment 

Posted on Oct. 24, 2023