August 04, 2017

CMS Announces Application Process for MIPS-ACI Hardship Exceptions

The Centers for Medicare and Medicaid Services (CMS) recently announced its manual application process for significant hardship exceptions from the Advancing Care Information (ACI) category of the Merit-based Incentive Payment System (MIPS). This exception reweights the ACI category to zero and reallocates those points to the quality category of MIPS.

Applying for a hardship exception is only necessary for MIPS-eligible clinicians who seek to reweight the ACI category and were not determined by CMS to be “hospital-based” or “non-patient-facing” for the MIPS performance year in question.

Hospital-based and/or non-patient-facing MIPS-eligible clinicians are automatically reweighted by CMS, based on their special status. Therefore, most ACR members will not need to apply. ACR members can look up their special statuses using CMS’ online lookup tool.

The three acceptable reasons for applying for a hardship exception from ACI are:

  1. insufficient Internet connectivity
  2. extreme and uncontrollable circumstances
  3. lack of control over certified electronic health record (EHR) technology availability.  

CMS will consider, approve or dismiss applications on a case-by-case basis.

Special statuses and hardship exception application options are discussed in more detail in this January 2017 ACR Advocacy in Action article.