• MIPS 2018—PI: Some Exceptions Are Automatic

    Written By: Rebecca Hancock, Flora Lum, MD, Chris McDonagh, Cherie McNett, Jessica Peterson, MD, MPH, and Sue Vicchrilli, COT, OCS

    This content was excerpted from EyeNet’s MIPS 2018; also see the Academy’s MIPS hub page


    Hospital- and ASC-based clinicians get an automatic exception. CMS will automatically excuse hospital-based clinicians and ambulatory surgical center (ASC)–based clinicians from having to report the PI performance category. Clinicians are assigned to those categories if, based on a review of historic data, at least 75% of their covered professional services have Place of Service codes that represent hospitals or ASCs, respectively. CMS has said that it will notify you if it deter­mines that you are a hospital- or ASC-based clinician. 

    NPs, PAs, CNSs, and CRNAs get an automatic exception. Nurse practitioners, physician assistants, clinical nurse specialists, and certified registered nurse anesthetists weren’t part of the EHR meaningful use program. Consequently, CMS isn’t sure whether they have enough applicable measures to succeed at PI and has automatically excused them from ACI in 2017 and PI in 2018. 

    Non–patient-facing clinicians get an automatic exception. If you don’t interact with patients face-to-face and fall under the definition of non–patient-facing MIPS eligible clinician, CMS will automatically apply the significant hardship exception.

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