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Mid-Week MACRA Minute – December 31 DEADLINES

Helping you put the MIPS pieces together each week!

DECEMBER 31st Deadlines:

  1. Quality Payment Program (QPP) 2017 Hardship Exception Application for the ACI category
  2. Virtual Groups Registration for 2018 MIPS Participation
  3. Security Risk Analysis for 2017 MIPS Participation

See below for details on each of these deadlines:

The Quality Payment Program (QPP) 2017 Hardship Exception Application for the ACI Category

MIPS eligible clinicians (ECs) and groups may qualify for a reweighing of their Advancing Care Information performance category score to 0% of the final score. The 25% weighting of the ACI performance category would be reallocated to the Quality performance category. MIPS ECs may submit a hardship exception application by DECEMBER 31, 2017, for one of the following specified reasons:

  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of Certified EHR Technology (CEHRT)

There are 2 ways to submit an ACI hardship application:

  • Visit the Quality Payment Program website and click on ‘Apply for a Hardship Application’.
  • Eligible clinicians may also contact the Quality Payment Program Service Center and work with a representative to verbally submit an application. Contact the Quality Payment Service Center at 1-866-288-8292 or TTY: 1-877-715-6222 or [email protected].

To submit an application, you will need:

  • Your Taxpayer Identification Number (TIN) for group applications or National Provider Identifier (NPI) for individual applications
  • Contact information for the person working on behalf of the individual clinician or group, including first and last name, e-mail address, and telephone number
  • Selection of hardship exception category (listed above) and supplemental information

Once an application is submitted, CMS will send a confirmation email that your application was submitted and is pending, approved, or dismissed. Applications will be processed by CMS on a rolling basis.


Some MIPS eligible clinicians are considered Special Status and will be automatically reweighed and do not need to submit a Quality Payment Program Hardship Exception Application. These circumstances are applicable for clinicians in: Health Professional Shortage Area (HPSA), Rural, Non-patient facing, Hospital Based, and Small Practices.

To find out more about how CMS calculated the Special Status visit:


To submit a hardship application or for more details regarding the ACI Hardship Exception visit the QPP website at or visit the MediSYS website at


Virtual Groups Registration for 2018 MIPS Participation Deadline is December 31, 2017

Virtual Groups is a new participation option for year 2. (**NOTE this is only for 2018 MIPS participation) A virtual group consists of 2 or more TINs including solo providers or groups of 10 or less ECs who work together, no matter specialty or location, to participate in MIPS.

Virtual groups will benefit small and rural practices to help them achieve the goals of MACRA by coming together to share financial risk and working towards a shared goal. Virtual Groups delivery system offers joint accountability, providing the ability to improve the cost, quality and experience of care.

To form a virtual group for 2018, solo practitioners and groups would need to engage in an election process. For the 2018 MIPS performance period, the election period DEADLINE for virtual groups to make an election is December 31, 2017.

Click the link here to download the Virtual Groups Toolkit with detailed information on the election process:


Update Security Risk Analysis for 2017 MIPS Participation

Providers must complete or update their Security Risk Analysis for their clinic prior to December 31, 2017. This is required for 2017 Medicaid EHR attestation AND 2017 MIPS (Medicare) Participation.