As part of MIPS reporting for Performance Year, Eligible 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 rehab providers, whose practice is in a free-standing rehab facility (such as Encompass Health), there is probably no capability of using an EHR system which satisfies CMS’ physician requirements – Encompass Health’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,” or

– “Eligible Clinician in a Small Practice”(under 15 clinicians).

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.

Additional information regarding this exception can be found at:

This article was contributed by Bruno Stillo, CPA, MBA, Physiatry Billing Specialists, 800-835-4482,
[email protected]