Things do not always go according to plan—and when uncontrollable circumstances arrive, a practice’s plan for meeting federal reporting requirements can suffer. To support practices experiencing hardship, the Centers for Medicaid & Medicare Services (CMS) created exceptions for Quality Payment Program (QPP) federal reporting. These applications are open to all Merit-based Incentive Payment System (MIPS)-eligible clinicians and are applicable to both Traditional MIPS and the Advancing Rheumatology Patient Care MIPS Value Pathway (MVP).
Exception applications for 2025 are currently open; the deadline to apply is Dec. 31.
Available MIPS Exceptions
The Extreme and Uncontrollable Circumstances (EUC) Exception allows clinicians to request reweighting for any or all performance categories if they encounter a circumstance deemed extreme and uncontrollable or a public health emergency outside of their control. Historic examples include the COVID-19 pandemic, wildfires and flooding. According to the CMS, allowable circumstances would:
- Cause the clinician to be unable to collect information necessary to submit for a MIPS performance category;
- Cause the clinician 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 they were unable to collect data for the Quality performance category for three months); and/or
- Impact the clinician’s normal processes, affecting their performance on cost measures and other administrative claims measures.
The MIPS Promoting Interoperability (PI) Hardship Exception allows clinicians to request reweighting specifically for the Promoting Interoperability performance category. This exception is available to MIPS-eligible clinicians, groups and virtual groups that can cite one of the following reasons:
- The practice has decertified electronic health record (EHR) technology;
- The practice has insufficient internet connectivity;
- The practice faces extreme and uncontrollable circumstances, such as disaster, practice closure, severe financial distress or vendor issues; and/or
- The practice lacks control over the availability of certified EHR technology.
Automatic EUC Exceptions
The CMS extends automatic EUC exception policies in response to disaster declarations by the Federal Emergency Management Agency (FEMA) and Department of Health & Human Services (HHS). Covered clinicians do not need to take action; their 2025 MIPS performance categories are automatically reweighted to 0%, earning them a neutral payment adjustment.
It is important to note that included clinicians will still have the option to submit data for 2025 MIPS programs if they have the goal of receiving a positive payment adjustment. The automatic exception simply removes the chance of a clinician’s MIPS score being negatively impacted by circumstances outside of their control.
Currently, the CMS has extended two automatic EUC exceptions for 2025 MIPS:
- California Wildfires and Straight-line Winds (DR-4856-CA)
- Texas Severe Storms, Straight-line Winds, and Flooding (DR-4879-TX)
If your practice has been impacted by a disaster, review the CMS’ 2025 MIPS Automatic Extreme and Uncontrollable Circumstances Policy Fact Sheet. This resource outlines the automatic EUC exception policy and is frequently updated as new automatic exceptions are announced.
Applying for an Exception
Both the EUC and PI exception applications are currently open. To complete an application, you will need a Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) account. For information on acquiring a HARP account, refer to the QPP Access User Guide.
To apply for an exception, visit the QPP’s Exception Applications webpage. Applications will close on Dec. 31.