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  • MIPS 2019—PI: Some Clinicians May Be Excused From Promoting Interoperability

    This content was excerpted from EyeNet’s MIPS 2019; also see the Academy’s MIPS hub page

    In limited circumstances, you may be able to skip PI reporting. Typically, if you don’t report PI measures, your PI score will be 0% and your maximum MIPS final score would be 75 points. However, there are some exceptions (see below). If you qualify for an exception, you would be excused from reporting PI measures. Some PI exceptions must be applied for, while others are automatic.

    What happens if you are excused from PI? If CMS excuses you from reporting PI, the performance category’s weight within your MIPS final score could be reduced to 0%. If PI is the only performance category that is being reweighted to 0%, its weight is transferred to the quality performance category, which would now be weighted at 70%, meaning that it could contribute up to 70 points toward your MIPS final score. If more than one performance category is being reweighted to 0%, see Table 5: Reweighting the Performance Categories.

    Warning: If you do any PI reporting for the 2019 performance year, you will have waived your right to any exception from PI. Suppose you qualify for a PI exception, but you report PI measures anyway. CMS will assume that you decided to participate in PI, will assign you a PI score, and will give PI a weight of 25% when calculating your MIPS final score.

    Caveat for group-level reporting. If you are participating in MIPS as part of a group, you won’t be excused from PI unless all MIPS eligible clinicians in the group are excused.

    Some PI Exceptions Must Be Applied For

    You may apply for a significant hardship exception. CMS has described several circumstances that might qualify for the significant hardship exception:

    • insufficient internet connectivity and insurmountable barriers prevented you from obtaining sufficient access;
    • extreme and uncontrollable circumstances that caused your CEHRT to become unavailable, including disaster, practice closure, severe financial distress (e.g., bankruptcy or debt restructuring), and vendor issues;
    • you have no control over whether CEHRT is available (you must be able to show that more than 50% of your patient encounters occurred in locations where you had no control over the availability of CEHRT);
    • you’re using a decertified EHR system that lost its certification in 2018 or 2019 (though you must be able to show a good faith effort to replace it with a CEHRT); and
    • you’re in a small practice and you can demonstrate that there are “overwhelming barriers” that prevent you from complying with the PI requirements.

    Note: If your practice lacks an EHR system, that is not enough, in and of itself, to excuse you from being scored on the PI performance category.

    Submit your application by Dec. 31, 2019. When can you start submitting applications for the PI hardship exception? This year, CMS opened the application process in August. 

    Want tips on submitting this application? The Academy has posted some guidance on its Medicare pages.

    Note: If you applied for this exception in 2018 and it was approved, the approval doesn’t roll over to 2019—you need to reapply for it annually. 

    Some Exceptions Are Automatic

    You’re in a disaster zone. If your practice is in an area that CMS has identified as being affected by extreme and uncontrollable circumstances, such as a natural disaster, CMS may automatically excuse you from PI.

    Certain types of MIPS eligible clinicians qualify for automatic reweighting. These include the following clinician types:

    • hospital-based clinicians,
    • ambulatory surgical center (ASC)–based clinicians,
    • non–patient-facing clinicians,
    • physician assistants,
    • nurse practitioners,
    • clinical nurse specialists,
    • certified registered nurse anesthetists,
    • physical therapists,
    • occupational therapists,
    • qualified speech-language pathologists, or
    • registered dietitians or nutrition professionals.

    Previous: PI: How You’ll Be Scored

    Next: Table 10: Promoting Interoperability at a Glance

    DISCLAIMER AND LIMITATION OF LIABILITY: Meeting regulatory requirements is a complicated process involving continually changing rules and the application of judgment to factual situations. The Academy does not guarantee or warrant that regulators and public or private payers will agree with the Academy’s information or recommendations. The Academy shall not be liable to you or any other party to any extent whatsoever for errors in, or omissions from, any such information provided by the Academy, its employees, agents, or representatives.

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