CMS clarifies 'special status' selection process for Quality Payment Program

CMS updated its website for the Quality Payment Program (QPP) recently with new information clarifying which clinicians will have “special status” and may be exempt from submitting data this year.

The agency also has a tool available online which providers can use to check to see whether they are exempt from participation in the Merit-based Incentive Payment System (MIPS), one of two payment pathways under the QPP.

Individual clinicians who may be exempt from participation include:

• Clinicians billing under a small practice of 15 or fewer clinicians
• Clinicians furnishing at least 75% of covered professional services in the inpatient hospital, on-campus outpatient hospital, or ED settings
• Clinicians in practices located in zip codes designated as rural by the most recent Health Resources and Services Administration’s area health resource file data
• Health Professional Shortage Area (HPSA) practices designated under section 332(a)(1)(A) of the Public Health Service Act
• Non-patient facing clinicians with 100 or fewer Part B patient-facing encounters

Practices that may be exempt from participation include:

• Practices in which all clinicians are hospital-based, with more than 75% of covered professional services furnished in the inpatient hospital, on-campus outpatient hospital, or ED settings
• Practices with 15 or fewer clinicians billing under the practice
• Practices with at least one practice site designated as rural
• Practices with at least one practice site in a HPSA
• Practices with more than 75% of NPIs under the practice’s tax identification number qualifying as non-patient facing clinicians

More information on special status qualification is available on the CMS website. Providers should pay attention for the release of the QPP final rule later this year to learn more about eligibility requirements for participation in the program next year. Information on the QPP proposed rule is available here.  

Update: After publication of this article, CMS released a correction on August 8 stating that "special status" does not mean a clinician or groups are exempt from participation in the QPP. The agency's correction stated: 

On July 24, CMS distributed an email update with an explanation for its special status calculation for the QPP. The message incorrectly stated that clinicians considered to have "special status" would be exempt from the QPP. Special status affects the number of total measures, activities, or entire categories that an individual clinician or group must report. Individual clinicians or groups with special status are not exempt from the QPP because of their special status determination.

Per CMS's correction to their previous guidance, the parameters in the article above will be used to determine if an individual clincian or groups are eligible for special status. The above parameters will not be used to exempt individual clincians or groups from participation.