Goodbye COVID Free Pass, Hello MIPS Exceptions

The Merit-based Incentive Payment System (MIPS) free pass may not return in 2022. The Centers for Medicare & Medicaid Services (CMS) exempted many clinicians from MIPS reporting in 2020 and 2021 due to COVID-19. But most clinicians will have to report their 2022 MIPS data when the window opens in January 2023. However, clinicians can still file for one of two hardship exceptions that simplify the process.

What Are MIPS Exceptions?

CMS created the MIPS exceptions for clinicians who cannot report data or meet performance criteria due to circumstances beyond their control. 

Types of Exceptions

Clinicians can apply for an exception if COVID-19disruptions hindered their ability to fulfill MIPS requirements. There are two options to choose from:

1. The Extreme and Uncontrollable Circumstances Exception (EUC) allows clinicians to skip reporting on one or multiple MIPS performance categories.
2. The Promoting Interoperability (PI) Performance Category Hardship Exception removes the reporting requirement for PI.

The PI category has proven challenging for clinicians due to its reliance on patients and third parties. PI counts for 25% of the final score for those reporting via traditional MIPS and 30% for APMs. With an exception, CMS automatically reweights those percentages to the quality and improvement categories. Clinicians have more control over these categories, so a PI exception can clear the path to higher scores.

How To Apply for a MIPS Exception

Clinicians with a HCQIS Access Roles and Profile (HARP) account can submit an application for either exception via the Quality Payment Program Portal. The applications are under the “Exceptions Application” link on the left-hand window. CMS will take applications for the 2022 reporting year until 8 p.m. ET on December 31, 2022. Visit CMS to register for a HARP account if you do not have one already.

To claim a PI exception, CMS states that you must meet one of the following criteria:

• You have decertified EHR technology
• You have insufficient internet connectivity
• You face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues
• You lack control over the availability of certified electronic health record technology (CEHRT)
• According to CMS, you can claim an EUC Exception if your circumstances:
• Cause you to be unable to collect information necessary to submit for a MIPS performance category
• Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time
• Impact your normal processes, affecting your performance on cost measures and other administrative claim measures

How To Prepare for the Future

The end of the COVID-19 free pass is not the only big change this year. CMS frequently modifies the MIPS program, so clinicians need to stay up-to-date to ensure compliance and avoid financial penalties. For the2022 reporting year, CMS also added:

• Seven new improvement activities and 15 revised ones
• Five new measures to the cost category
• Social workers and nurse-midwives to the list of required reporters
• Automatic reweighting of the PI category for some small practices

While the exceptions may give clinicians a break from the burdensome PI measures in 2022, the category will likely expand in the future. CMS' stated goal for PI is to improve health outcomes by promoting a structured exchange of health information. They have continually evolved the program since its creation in 2011 (then known as meaningful use).

A final rule from CMS regarding the 2023 program year is expected by November. It should detail new reporting requirements for PI as well as any changes to the exceptions. We do already know that in 2023 clinicians will be able to report their data via the new MIPS Value Pathway (MVP) framework.

Clinicians who miss these important changes risk losing valuable points from their scores. See how ChartPath avoids this by helping practices navigate the new MVP system, PI, and all other things MIPS.

How ChartPath Can Boost Your MIPS Score

Clinicians need a score of 75 points on their 2022 data to avoid a financial penalty in 2024. A MIPS exception can increase your odds of scoring above this mark. However, CMS may remove the exceptions in the future or no longer allow them for COVID-19. And even with an exception, clinicians must maintain detailed and accurate medical records.

ChartPath is a leader in long-term post-acute care (LTPAC) charting solutions that maximize practice efficiency and profitability. Schedule a demo today to see how our EHR simplifies the charting experience for LTPAC clinicians. With soft/hard stops and a convenient MIPS dashboard, we help you achieve the highest MIPS score possible.