MIPS ACI Hardship Exceptions 2017

If you are an Eligible Clinician (EC) reporting for MIPS in 2017 but have had the following hurdles:

  • Insufficient Internet Connectivity
  • Extreme and Uncontrollable Circumstances
  • Lack of Control over the availability of CEHRT

You may qualify for a hardship exception.  By visiting, https://qpp.cms.gov/about/hardship-exception , you can learn more about these categories and use a link to fill out an online application. This application does not guarantee you a hardship, but you will hear back from CMS with their determination.

Some clinicians, named “Special Status Clinicians”, can automatically be exempt from the ACI category. Simply by not submitting ACI data, CMS will auto-exempt you from ACI. These clinician types may take advantage, if appropriate, for this option.

  • Hospital-based MIPS-eligible clinicians
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Non-patient facing clinician

Of course, if a “Special Status Clinician” does have ACI data to submit, please weigh the benefits/disadvantages to submitting or taking the exception. 

For either option, CMS will reweigh the ACI category to 0%  and add the 25% to the Quality category, which will make the Quality category worth 85% of the final MIPS score. The Improvement Activities score would remain at 15%.


Writers:  PHA Managing Advisors Jennifer Anglin and Wayne Fischer.

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