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The 2019 Quality Payment Program (QPP) Exception Applications for the Merit-based Incentive Payment System (MIPS) performance categories are available on the QPP website.

Promoting Interoperability  Hardship Exceptions If you are participating in MIPS during the 2019 performance year as an individual, group, or virtual group, you can submit a QPP Hardship Exception Application for the PI performance category. It also applies if you are participating in a MIPS Alternative Payment Model (APM). You have to submit your application by December 31 for CMS to re-weight your PI performance category to 0%.

Hardship Exception can be submitted until December 31 of 2019 

Extreme and Uncontrollable Circumstances

MIPS eligible clinicians that are affected by extreme and uncontrollable circumstances may submit a request for re-weighting the Quality, Cost, and Improvement Activities
performance categories. Claimants should submit the application by December 31 for the 2019 MIPS performance year. 

Promoting Interoperability Hardship Exception

Certifified Electronic Health Record Technology (CEHRT) is necessary when you want to participate in the Promoting Interoperability performance category. Under the Merit-based Incentive Payment System (MIPS), you may qualify for a reweighting of the Promoting Interoperability performance category (to 0%) if you meet certain criteria.

Can I Apply for a PI Hardship Exception?

MIPS eligible clinicians, groups, and virtual  groups may submit a Promoting Interoperability Hardship Exception Application if they can cite at least one of the following reasons:
• They operate a small practice
• They have decertified EHR technology
• They have insufficient Internet connectivity
• They have faced extreme and uncontrollable circumstances such as disasters, practice closure, severe financial distress, or vendor issues, among other
• They lack control over the availability of CEHRT NOTE: If you're already exempt from submitting Promoting Interoperability, you don't need to apply for this application. Also, the
lack of CEHRT does not qualify anyone for reweighting.

Automatically Exempted from PI Reporting 

You're exempt from reporting Promoting Interoperability if you're identified on the QPP Participation Status Tool as:
• Ambulatory Surgical Center (ASC),
• Hospital-based, or;
• Non-patient facing The following clinician types also are exempt from reporting PI:
• Physician assistants
• Nurse practitioners
• Clinical nurse specialists
• Certified registered nurse anesthetists
• Physical therapists
• Occupational therapists
• Qualified speech-language pathologists
• Qualified audiologists
• Clinical psychologists
• Registered dietitian or nutrition professionals

How do I Apply?

The Promoting Interoperability Hardship Exception Application for Performance Year 2019 is now open. The application window will close on December 31, 2019. To apply, make sure you have the following information:
• For an individual application: the clinician's NPI, group name, and group TIN
• For a group application: group name and TIN
• Or a VG (virtual group) application: VG ID 

What happens if my Application is approved?

If your application is approved, you do not have to report for the Promoting Interoperability performance category and the category will be re-weighted to 0% of your final score. The 25% weighting of the Promoting Interoperability performance category will be reallocated to the Quality performance category.

How do I know if I’m approved?

You'd be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile in the QPP Participation Status lookup tool. However, it may not appear in the lookup tool until the submission window is open in 2020. 

Take note that your application may be put into pending status, as well. If this happens, you will be notified by email. If your application is in pending status, CMS will check after the 2nd MIPS eligibility determination segment and see if you have billed any Medicare Part B data. If you have, they will approve the application.

Extreme and Uncontrollable Circumstances Exception

MIPS eligible clinicians, groups, and virtual groups may apply for re-weighting of any or all MIPS performance categories if they've been affected by extreme and uncontrollable
circumstances that extend beyond the Promoting Interoperability performance category.

Can I Apply for an Extreme and Uncontrollable Circumstances Exception?

Extreme and uncontrollable circumstances refer to rare events entirely outside of your control and the control of the facility in which you practice.
These circumstances would cause you to either be:
• Unable to collect information necessary to submit for a performance category or;
• Unable to submit the information that would be used to score a performance category for an extended period of time, as for example, if you were unable to collect data for the Quality performance category for three months.

When Does This Exception get Applied Automatically?

The automatic extreme and uncontrollable circumstances policy applies to MIPS eligible clinicians who are located in a Centers for Medicare & Medicaid Services-designated region that have been affected by an extreme and uncontrollable event (such as FEMA-designated major disaster) during the 2019 MIPS performance period. 
The automatic extreme and uncontrollable circumstances policy does not apply to group or virtual group participation.

MIPS performance year comes to a close. Refer to page 25 of the WCH Insights July issue and do not miss the deadline for reporting MIPS for 2019! Know how to avoid Negative adjustments!

How do I Apply?

The Extreme and Uncontrollable Circumstances Application for Performance Year 2019 is now open. The application window will close on December 31, 2019. To apply, make sure you have the following information:
• For an individual application: the clinician's NPI, group name, and group TIN
• For a group application: group name and TIN
• Or a VG (virtual group) application: VG ID 

How do I know if I’m approved?

You'd be notified by email if your request was approved or denied. If  approved, this will also be added to your eligibility profile in the QPP Participation Status Tool. It may, however, not appear in the lookup tool until the submission window is open in 2020.

Note that your application may be put into pending status, in  which case you will be notified by email. If your application is in pending status, CMS will check after the 2nd MIPS eligibility determination segment and see if you have billed any Medicare Part B data. If you have, they will approve the application.

What happens if My Application is approved?

If your application is approved, you do not have to report for the requested performance category or categories, and those categories will be re-weighted.

October is the Start of the Last 90-Day Reporting Period for the  MIPS! The Payment Adjustment is set to the range from -7 % to + 7 % for Medicare payments in 2021 for the performance year 2019! Contact us today!

For More Information: • QPP website • QPP Resource Library webpage • QPP Webinar Library webpage • For questions, contact your local technical assistance organization,, or 1-866-288-8292 (TTY: 1-877-715-6222).

We are here to Help!

WCH team is willing and able to provide assistance and find answers for you if you feel overwhelmed. MIPS services include, consultations on all reporting measures and
suggestions what to report, also we help with registration and keep up to date on all benefits and due dates. Contact us today!


In general, health insurance carriers have different time limits for claims submission. They do not accept claims for processing when submitted after the time limit has been exhausted. Since time limits vary from payer to payer and plan to plan, in-network and out-of-network providers must know the timeframe within which they have to work.

Payers may have general timely filing requirements. It must be followed when in the provider’s agreement (with insurance), no specific time limit is indicated. Otherwise, the contract supersedes the general timely filing regulations. Commercial payers may have a time limit for initial claim submission as short as 90 days. As for Workers’ Compensation and No-Fault cases, it’s usually 45 days.

Don't be late otherwise you won't get paid.

Although providers may have 90 days for claim submission,  providers have to consider that WCH submits claims to healthcare payers within five business days after superbills
receipt. In some circumstances, additional time may be required for billing requests in cases when some information is missing on superbills.

Send Superbills for processing within 30 days after the DOS!

For Workers Compensation and No-fault payers, additional  time is required for mailing. To avoid any filing denials, we encourage providers to submit all superbills (for processing with full and accurate information) within 30 days after the date of service. For Workers Compensation and No-fault payers, complete package should be submitted the latest within a week.

Below are the time limits for major payers in NY and NJ

Issues schedule

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September 2019