• MIPS 2018—PI: Some Exceptions May Be Applied For

    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


    You may apply for a significant hardship exception. Clinicians facing a significant hardship, such as insufficient internet access or extreme and uncontrollable circumstances, can apply for CMS to reweight their PI score. If you were approved for this exception in 2017, the approval doesn’t roll over to 2018—you need to reapply annually.

    New—CMS invites small practices to apply for a significant hardship exception. If your practice has 15 or fewer eligible clinicians, you can apply for an PI exception. In this application, you are expected to demonstrate that there are “overwhelming barriers” that prevent you from complying with the PI requirements. What would CMS consider to be an overwhelming barrier? The regulations offer little guidance, but they do say, “we do not intend to require documentation of the overwhelming barriers.”

    New—if your EHR system loses its CEHRT certification, you may apply for an exception. If your EHR system is decertified in 2017 or 2018, you can apply for an exception from PI in 2018. In your application, you are expected to demonstrate that you made a good faith effort to implement a replacement CEHRT.

    Submit your application by Dec. 31, 2018. Based on last year’s timeline, you can expect CMS to start accepting applications online in late August.

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    Previous: PI: Some Clinicians May Be Excused From Promoting Interoperability (Formerly ACI).

    Next: PI: Some Exceptions Are Automatic.

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