This content is excerpted from EyeNet’s MIPS 2022: A Primer and Reference; also see the Academy’s MIPS hub page.
In limited circumstances, you may be excused from 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 weighting within your MIPS final score could be reallocated to one or more other performance categories as shown in “Table 1: How the Performance Categories Are Weighted.”
Warning: If you do any PI reporting for the 2022 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 (rather than as an individual), 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); and/or
- you’re using a decertified EHR system that lost its certification in 2021 and 2022 (though you must be able to show a good faith effort to replace it with a CEHRT ahead of the performance period, and you can't be granted this exception for more than five years).
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 Jan. 3, 2023. To apply for the exception, go to this page, https://qpp.cms.gov/mips/exception-applications, and scroll down. (Note: CMS had initially set a Dec. 31 deadline, but has changed that to Jan. 3 for performance year 2022.) (Update: On Dec. 29, CMS announced that it was extending the EUC deadline to March 3 at 8:00 p.m. ET if you are citing the COVID-19 public health emergency as the triggering event. The agency also noted that any EUC applications that it receives between Jan. 3 and March 3 wouldn't override any data that had been submitted.)
Want tips on submitting this application? See the Academy’s guidance.
The exception is only good for one year at a time. If you applied for this exception in 2021 and it was approved, the approval doesn’t roll over to 2022—you need to reapply.
Some PI 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 excuse you from MIPS provided you don't report any MIPS data.
New for 2022: You are in a small practice. Previously, you had to apply for the small practice hardship exception. In 2022, if you don’t report on PI and CMS has designated your practice size as small, a hardship exception will automatically apply.
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,
- registered dietitians or nutrition professionals,
- (new for 2022) clinical social workers, and
- (new for 2022) certified nurse-midwives.
Reminder. Although you may be eligible for a PI exception, you will waive your right to that if you submit any PI data to CMS.
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