CMS Accepting 2023 MIPS Extreme and Uncontrollable Circumstances Exception and MIPS Promoting Interoperability Performance Category Hardship Exception Applications

October 20, 2023
Policy Snapshot

The Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances (EUC) Exception and MIPS Promoting Interoperability Performance Category Hardship Exception applications are available for the 2023 performance year. Applications can be submitted until 8:00 PM ET on January 2, 2024.

MIPS Extreme and Uncontrollable Circumstances Exception Application

MIPS-eligible clinicians, groups, and virtual groups may apply to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances, which are defined as rare events entirely outside of your control and the control of the facility in which you practice. These circumstances must:

  • 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)
  • Impact your normal process, affecting your performance on cost measures and other administrative claims measures

For Alternative Payment Model (APM) Entities

APM Entities participating in MIPS APMs can also submit a MIPS EUC Exception application. However, the policy for APM Entities differs from the MIPS EUC policy for individuals, groups, and virtual groups in that:

  • APM Entities are required to request reweighting for all performance categories
  • At least 75% of an APM Entity’s MIPS-eligible clinicians must qualify for reweighting in the Promoting Interoperability performance category
  • Data submission for an APM Entity won’t override performance category reweighting

Learn more in the 2023 MIPS Extreme and Uncontrollable Circumstances Application Guide.

MIPS Promoting Interoperability Performance Category Hardship Exception Applications

MIPS-eligible clinicians, groups, and virtual groups may apply to reweight the Promoting Interoperability performance category to 0% if they:

  • Have decertified electronic health record (EHR) technology
  • Have insufficient Internet connectivity
  • Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues (or)
  • Lack control over the availability of certified EHR technology (CEHRT); simply lacking the required CEHRT doesn’t qualify you for reweighting

Note: You don’t need to apply for this application if you qualify for automatic reweighting of the Promoting Interoperability performance category based on your clinician type or special status.

As a reminder, small practices qualify for automatic reweighting. Refer to Appendix A of the 2023 MIPS Promoting Interoperability User Guide for a complete list of clinician types and special statuses that qualify for automatic reweighting in the 2023 performance year. Learn more in the 2023 Promoting Interoperability Hardship Application Guide.

How do I Apply?

You must have a Health Care Quality Information Systems (HCQIS) Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself, or another MIPS eligible clinician, group, virtual group or APM Entity. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you register for a HARP account, sign in to the QPP website, select ‘Exceptions Applications’ on the left-hand navigation, select ‘Add New Exception,’ and select ‘Extreme and Uncontrollable Circumstances Exception’ or ‘Promoting Interoperability Hardship Exception.'

Note for Subgroups

Subgroups will inherit any reweighting approved for their affiliated group; if the subgroup encounters an extreme and uncontrollable circumstance that doesn’t affect the entire group, the subgroup can contact the QPP Service Center to request reweighting.

How do I Know if I’m Approved?

You'll be notified by email if your request was approved or denied. You can also check the status of your application by signing in to the QPP website and navigating to ‘Exceptions.’ If approved, this information will also be added to your eligibility profile in the QPP Participation Status Tool on a weekly basis. If your application is approved at the end of the performance year, it may not appear until the submission window opens on January 2, 2024.