The Centers for Medicare & Medicaid Services (CMS) recently opened the 2025 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances (EUC) Exception and Promoting Interoperability (PI) Hardship Exception applications. Notably, CMS has expanded eligibility criteria to allow exemptions from the Cost performance category and administrative claims-based measures, providing significant relief for practices facing operational disruptions for an extended period, for example due to a cyberattack.

Individual clinicians, groups and virtual groups can submit a MIPS EUC exception application for one or more MIPS performance category (quality, cost, improvement activities, and Promoting Interoperability) due to extreme and uncontrollable circumstances for the 2025 MIPS performance period now through Dec. 31, 2025, at 8:00 p.m. Eastern time.   

Alternate Payment Model (APM) entities can submit applications as well, but they must apply for all performance categories. 

Key updates for 2025:

• Expanded EUC exceptions: Physicians, groups and virtual groups can apply for reweighting of one or more MIPS performance categories—Quality, Cost, Improvement Activities, and Promoting Interoperability—if they experience circumstances that:
  • Prevent data collection necessary for MIPS reporting.
  • Hinder data submission for an extended period (e.g., inability to collect quality data for three months).
  • Disrupt normal operations, affecting performance on Cost measures and other administrative claims-based measures.
• PI hardship exceptions: Eligible clinicians may request reweighting of the Promoting Interoperability category due to:
  • Decertified electronic health record (EHR) technology.
  • Insufficient internet connectivity.
  • Extreme and uncontrollable circumstances such as natural disasters, practice closures, severe financial distress, or vendor issues.
  • Lack of control over the availability of certified EHR technology.

These updates offer critical flexibility to address unforeseen challenges that may impact MIPS reporting. Practices are encouraged to assess their eligibility and submit applications as needed to avoid potential payment penalties.

If your application is approved, you will not be required to report data for the performance category or categories included in your approved application. However, please note that a qualifying data submission will override approved reweighting on a category-by-category basis. Any qualifying data you, or someone on your behalf, submits will be scored, and those performance categories will contribute to your final score. 

For more information and to access the applications, visit the QPP Exception Applications page.