What to Know: MIPS Category Hardship and Extreme and Uncontrollable Circumstance Applications

The 2022 MIPS performance year is quickly drawing to a close. With high performance stakes and reimbursement on the line your outcomes are key. However, there may be a critical reason that you need to or may be eligible to sit out for the year with a hardship or extreme and uncontrollable circumstances application. Over the last two years there were mass exemptions for MIPS eligible clinicians, resulting from the COVID pandemic. However, in 2022 to qualify for an exemption or hardships you need to understand how and if you qualify. Here's what you need to know.

What is a category Hardship Application?

A hardship application is filed with the Centers for Medicare and Medicaid Services (CMS) to request an exemption from MIPS reporting. CMS has identified several reasons that may warrant a hardship exemption. Hardship exceptions are available for the following specified reasons:

  • 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 CEHRT

 Applicants must submit documentation that verifies the hardship.

What is an Extreme and Uncontrollable Circumstances Application?

An Extreme and Uncontrollable Circumstances (EUC) application is filed with CMS to request an exemption from MIPS reporting for natural disasters or other emergency situations that are out of the control of the MIPS eligible clinician. Applicants must submit documentation that verifies the EUC.

Documenting for either of these applications is key. It is imperative to write-up how and why you qualify to sit out for the performance year or category. What happened? Why was is so critical to you ability to have otherwise participated? Did it impact you for the whole year or disrupt operations for a significant period of time? Do you have supporting documentation to help substantiate the issue or circumstances? If so, all of ti need to be very well written up and confirmed.

When is the deadline to file?

The deadline to file a Hardship or EUC application for the 2022 MIPS performance year is March 3rd, 2023.

What are the consequences of not filing or not being approved?

If you do not submit a Hardship or EUC application by the deadline or if your application is denied, you will be required to participate in MIPS for the 2022 performance year. This means that you will be subject to the MIPS payment adjustment for the 2024 payment.

How to file an application

Download our free eBook on how to file.

What if I have more questions?

To get expert help documenting and filing you application or to learn more about Hardship and Extreme and Uncontrollable Circumstance Applications, please visit us at www.chirpybirdinc.com or email us at hello@chirpybirdinc.com

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