Claiming a Hardship Exception

CMS grants sweeping hardship exceptions. These exceptions are no longer granted automatically. To learn more, visit the QPP website. This page outlines the hardship exceptions.

You may submit an application to reweight any or all of the MIPS performance categories if you've been affected by extreme and uncontrollable circumstances that impact these performance categories. Applications are due by 5:00 p.m. (PT) on January 2, 2025.

Extreme and uncontrollable circumstances are defined as rare events entirely outside of your control and the control of the facility in which you practice. These circumstances would

  • Cause you to be unable to collect information necessary to submit for a MIPS performance category;
  • Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for 3 months); or
  • Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.

To submit a MIPS Extreme and Uncontrollable Circumstances application, follow these steps:

  1. Sign in to the QPP Portal with your HARP credentials.
  2. Select Exceptions Application on the left-hand navigation.
  3. Select Extreme and Uncontrollable Circumstances.

CMS will grant automatic EUC exceptions for eligible clinicians who are located in regions that have been affected by an extreme and uncontrollable event or a FEMA-designated major disaster, like Hurricanes Francine and Helene during the 2024 performance year. As of this writing, eligible clinicians in the following states will receive an automatic EUC exception: Florida, Georgia, Louisiana, North Carolina, South Carolina, and Tennessee.

CMS will identify all MIPS-eligible clinicians in these areas and reweight all four MIPS performance categories to 0% during the data submission period for the 2024 performance period. This will result in a score equal to the performance threshold, and those clinicians will receive a neutral payment adjustment for the 2026 MIPS payment year.

However, if MIPS-eligible clinicians in these areas submit data on two or more performance categories, they’ll be scored on those performance categories and receive a 2026 MIPS payment adjustment based on their 2024 MIPS final score.

The MIPS automatic EUC policy doesn’t apply to MIPS-eligible clinicians participating in MIPS as a group, subgroup, virtual group, or Alternative Payment Model (APM) entity. However, groups, virtual groups, and APM entities can request reweighting through the EUC exception application. Subgroups will inherit any reweighting approved for their affiliated group; they can’t request reweighting independent of their affiliated group’s status.

You may request a MIPS category reweighting by filing a Promoting Interoperability Performance Category Hardship Exception application by 5:00 p.m. (PT) on January 2, 2025. If CMS approves the exception application, ECs and groups will be scored on the categories for which they have submitted data.

Hardship exceptions are available for the following specified reasons:

  • You have decertified EHR technology
  • You have insufficient Internet connectivity
  • You face extreme and uncontrollable circumstances such as a disaster, practice closure, severe financial distress, or vendor issues
  • You lack control over the availability of a certified EHR

Simply lacking a certified EHR doesn't qualify you for reweighting.

If you're already exempt from submitting Promoting Interoperability data (e.g., small practices), you don't need to apply for this application

To submit a MIPS Promoting Interoperability Performance Category Hardship Exception application, follow these steps:

  1. Sign in to the QPP Portal with your HARP credentials.
  2. Select Exceptions Application on the left-hand navigation.
  3. Select Promoting Interoperability Hardship.