CMS flagging MIPS hardship, exception & virtual group deadlines

The Centers for Medicare & Medicaid Services (CMS) is reminding applicable physicians that the deadline to apply for a ‘Promoting Interoperability Hardship Exception’ or an ‘Extreme and Uncontrollable Circumstances Exception’ or to form a “virtual group” for the 2019 Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Merit-Based Incentive Payment System (MIPS) performance year is Tuesday, December 31.

CMS explains that, “MIPS eligible clinicians, groups, and virtual groups may qualify for a re-weighting of the Promoting Interoperability performance category to 0% if they: are a small practice; have decertified EHR technology; have insufficient Internet connectivity; face extreme and uncontrollable circumstances (e.g., disaster, practice closure, severe financial distress, vendor issues); lack control over the availability of CEHRT.”

CMS also notes that, “If you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply.”

As for the ‘Extreme and Uncontrollable Circumstances Exception,’ CMS says that, “MIPS eligible clinicians, groups, and virtual groups may qualify for a re-weighting of any or all MIPS performance categories to 0% if they are affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must render them unable to collect information necessary to submit for a performance category or submit information that would be used to score a performance category for an extended period of time.”

CMS stresses that, “Individual MIPS eligible clinicians (not groups or virtual groups) will receive the exception automatically if they are located in a CMS-designated region that has been affected by an extreme and uncontrollable event during the 2019 MIPS Performance Year. These clinicians will not need to apply for the exception.”

It adds that, “If you submit an application for either of the exceptions, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but [it] may not appear in the tool until the submission window is open in 2020.”

According to CMS, “A virtual group is a combination of two or more Taxpayer Identification Numbers (TINs) assigned to 1) one or more solo practitioners (who are MIPS eligible clinicians) or 2) one or more groups consisting of 10 or fewer clinicians (including at least one MIPS eligible clinician) or 3) both (solo practitioners and groups of 10 or fewer clinicians) that elect to form a virtual group for a performance period for a year.”

The virtual group election process includes two stages. An optional Stage 1 calls for applicants to, “Contact [their] Quality Payment Program Technical Assistance organization for information regarding TIN size to help [them] determine if [they] meet the TIN size criteria to join or form a virtual group.” Stage 2 requires applicants to, “Have a formal written agreement and name an official virtual group representative and submit the virtual group’s election via e-mail to CMS at”

Finally, CMS stresses that, “Clinicians in small practices (including those in rural locations), health professional shortage areas, and medically underserved areas may request technical assistance from on-the-ground organizations that can provide no-cost support.”

Contact CMS at or 866.288.8292 with questions.

‘Promoting Interoperability Hardship Exception’ web page

‘Extreme and Uncontrollable Circumstances Exception’ web page

QPP Participation Status web page

2020 Virtual Groups Toolkit

‘Support for Small, Underserved, and Rural Practices’ web page