In the August 4, 2017 edition of its Advocacy in Action eNews the American College of Radiology (ACR) reported on the Centers for Medicare and Medicaid Services (CMS) announcement regarding the manual application process for a significant hardship exception under the Advancing Care Information (ACI) category of MIPS.
There are three acceptable reasons to apply for a hardship exception, which would re-weight the ACI category to zero:
- Insufficient internet connectivity;
- Extreme and uncontrollable circumstances; or
- Lack of control over certified electronic health record (EHR) technology availability.
The ACR makes a distinction important to radiologists by writing, “Hospital-based and/or non-patient-facing MIPS-eligible clinicians are automatically reweighted by CMS, based on their special status.” Therefore, most radiologists will not need to apply for a hardship exception from the ACI category of MIPS.
There are other criteria that will affect the level of reporting in MIPS under the Quality Payment Program (QPP), as listed in this table from the CMS QPP website. For an individual physician, special status is afforded under the following circumstances:
| Special Status | Description | |
| Small practice |
|
|
| Non-patient facing | The clinician has 100 or fewer Medicare Part B patient-facing encounters (including Medicare telehealth services) during the non-patient facing determination period. | |
| HPSA | Practices in areas designated as Health Professional Shortage Areas under the Public Health Service Act. | |
| Rural | Practices in zip codes designated as rural, using the most recent Health Resources and Services Administration (HRSA) Area Health Resource File data. | |
| Hospital based | The clinician furnishes 75% or more of their covered professional services in the inpatient hospital, on-campus outpatient hospital, or emergency room settings (based on place of service codes) during the applicable determination period. Reviews are conducted each December using claims for services in the preceding September – August year. |
There are additional implications for radiologists practicing and reporting as a group under MIPS, as more fully explained in our article Exempt from MIPS? Think Again About Participating as a Group. Our article Why the MIPS Patient-Facing Rules are Important to Radiologists and other related articles posted on our radiology RCM blog explain the implications of the various special status exceptions listed in the table above.
Physicians or groups (when reporting for MIPS as a group) who meet the following criteria will be automatically exempt from QPP reporting in 2017 and do not need to make any application:
- Clinicians/groups who bill Medicare for $30,000 or less
- Clinicians/groups who have provided care for 100 Medicare patients or fewer
- Clinicians who enroll in Medicare for the first time in 2017 (exemption still applies to the individual clinician when the practice is reporting as a group)
For radiologists who are not automatically exempt, and who do not meet the requirements to apply for a hardship exception, there are many factors that go into the decision-making process to determine how to report and which measures and activities to select. Healthcare Administrative Partners is preparing a comprehensive guide that will help you make the right choices for your practice. Subscribe to this blog for further updates as they occur.
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