Frequently Asked Questions Updated for 2018


2. Is it possible for those practices without an EHR to apply for a hardship exemption?

  1. CMS has defined criteria for physicians and practices to apply for a “significant hardship” which would re-weight the advancing care information (ACI) category to 0% of the 2018 MIPS final score for MIPS eligible clinicians. The 25% ACI weight would be re-assigned to the quality performance category (for a total weight of 85% of the MIPS final score).

    The relevant significant hardships applicable to not having an EHR include:

    1. Insufficient Internet Connectivity
    2. Extreme and Uncontrollable Circumstances
    3. Lack of Control over the Availability of CEHRT
    4. MIPS eligible clinicians in small practices of 15 or fewer eligible clinicians
    5. Decertified EHR

    To learn more about the hardship criteria, please see the ACI Hardship Reweighting resource

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