QPP hardship application now open

The Centers for Medicare & Medicaid Services (CMS) is now accepting applications from individual physicians and medical groups that believe they are due hardship exceptions from the Quality Payment Program for the 2017 transition year.

As a reminder, physicians and groups eligible for the Merit-based Incentive Payment System (MIPS) under QPP must submit data in the advancing care information performance category with Certified Electronic Health Record Technology (CEHRT). The advancing care information category makes up 25 percent of the participant’s final score under MIPS. The program allows participants to have this performance category zeroed out and the 25 percent reallocated to the participant’s quality performance category if they qualify for a hardship exception.

The physician or group seeking the hardship exception must submit an application through the QPP website for one of three reasons:

• Insufficient internet connectivity
• Extreme and uncontrollable circumstances
• Lack of control over the availability of CEHRT

Besides submitting an application online, physicians can also contact the QPP Service Center at 1-866-288-8292 (TTY: 1-877-715-6222) and verbally submit an application.

To submit an application, you will need:

• Your Taxpayer Identification Number (TIN), if you are participating as a group, or your National Provider Identifier (NPI), if you are participating as an individual;
• Contact information for the participant submitting the application or their representative, including first and last name, e-mail address, and telephone number; and
• Which of the three hardship exception categories under which you are submitting the application.

If you are applying for a hardship exception based on extreme and uncontrollable circumstances, there are four types allowed:

• Disaster, such as a flood or fire that damaged or destroyed the CEHRT
• Practice or hospital closure
• Severe financial distress, such as bankruptcy or debt restructuring
• Issues with the certification of the CEHRT or the vendor

Applicants must select which type they are claiming and provide a start and end date for when the circumstance occurred.

After you submit an application, CMS will send a confirmation email that your application was submitted and is either pending, approved, or dismissed. CMS will process applications on a rolling basis.

Certain physicians are considered “special status” by CMS and automatically receive a QPP exception without having to submit an application. To determine if a physician has ‘special status” under QPP, CMS analyzes Medicare Part B claims data and calculates whether certain circumstances of the practice will affect the number of total measures, activities, or entire categories that the practice must report. These circumstances apply to:

• Physicians in rural and Health Professional Shortage Areas
• Physicians who do not interact directly with patients, such as pathologists
• Physicians based in hospitals
• Small practices

For more information, you can contact the QPP Service Center at 1-866-288-8292 (TTY: 1-877-715-6222) or by email at QPP@cms.hhs.gov. You can also visit the QPP website.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians