As part of MIPS reporting,  providers are required to report under the “Promoting Interoperability” category (formerly known as Advancing Care which was formerly known as EHR(Electronic Health Records)). For most hospital-based providers, whose practice is in a free-standing rehab facility (such as Healthsouth), there is no capability of using an EMR system which satisfies CMS’ physician requirements – Healthsouth’s system does not meet physician reporting requirements.

In order to avoid losing 25% of points in the MIPS Scoring system, these providers can submit a very simple Hardship Exception indicating “Lack of Control over the availability of CEHRT.” If approved, the application will move the 25% scoring from “Promoting Interoperability” to “Quality,” thus avoiding a loss of 25% scoring in the MIPS program.
The Promoting Interoperability Hardship Exception application can be found at:
The deadline is December 31, 2018, so there is still time to submit this simple application.

This information has been provided by Bruno Stillo, CPA, MBA, President, Physiatry Billing Specialists, 800-835-4482,
[email protected]