August 07, 2017
Area(s) of Interest: MACRA Payor Issues and Reimbursement Practice Management
The Centers for Medicare and Medicaid Services (CMS) is now accepting hardship exceptions from the Medicare Quality Payment Program (QPP) for the 2017 reporting year. Beginning with this reporting year, physicians who do not participate in QPP will see a negative 4 percent payment adjustment in 2019. Physicians who do participate may qualify for bonus payments.
Physicians and groups that qualify for the QPP’s Merit-Based Incentive Payment System (MIPS) can submit a hardship exception application for one of the following reasons:
- Insufficient internet connectivity
- Extreme and uncontrollable circumstances
- Lack of control over the availability of certified electronic health record technology
If you meet one of the criteria above, you may qualify for a reweighting of the Advancing Care Information performance category score to 0. The 25 percent weighting of the advancing care information category would be reallocated to the quality performance category
There are also some MIPS eligible clinicians who are considered “special status,” who will be automatically reweighted (or exempted in the case of MIPS eligible clinicians participating in a MIPS alternative payment model) and do not need to submit a QPP hardship exception application.
Hardship exception applications can be submitted via the QPP website. You can also contact the QPP Service Center at (866) 288-8292 or QPP@cms.hhs.gov and work with a representative to submit an application.
Once an application is submitted, you will receive a confirmation email that your application was received and is pending, approved or dismissed. Applications will be processed on a rolling basis.
Physicians should also be aware that 2017 is a transition year, with CMS offering “pick your pace” options for participation. Participating at any level in 2017 will ensure that you will not be hit with payment penalties in 2019. The most lenient participation option would allow physicians to simply "test" the program to ensure that their systems are working and that they are prepared for broader implementation in 2018 and beyond. While physicians who choose this option will not receive bonus payments, they will avoid a negative penalty.
Providers with less than $30,000 in Medicare payments or fewer than 100 Medicare patients are exempt from the MIPS reporting requirements. Physicians who exceed this threshold are subject to MIPS and are encouraged to participate in MIPS for the 2017 transition year to avoid the negative payment adjustment. If you are unsure of your MIPS participation status, click here.
California physicians in practices of 15 or fewer can receive free assistance to prepare and participate in Quality Payment Program through CalHIPSO. For more information visit www.hsag.com/CalHIPSO.
The American Medical Association has also published a short instructional video to help physicians avoid being penalized under the QPP. The video offers step-by-step instructions on how to report on one patient for one measure to avoid a negative 4 percent payment penalty in 2019.
For more information about the QPP, implemented with the Medicare Access and CHIP Reauthorization Act (MACRA), visit the MACRA Resource page.