There are 2 exception applications available to clinicians:

• The MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application allows you to request reweighting for any or all performance categories if you encounter an extreme and uncontrollable circumstance that's outside of your control.
• The MIPS Promoting Interoperability Performance Category Hardship Exception application allows you to request reweighting specifically for the Promoting Interoperability performance category if you qualify for one of the reasons identified below.

MIPS EUC Exception

MIPS eligible clinicians, groups, and virtual groups may submit an application to request reweighting of any or all MIPS performance categories if they've been affected by extreme and uncontrollable circumstances that impact these performance categories and aren’t covered by the automatic extreme and uncontrollable circumstances policy (see below). Clinicians that register to report a MIPS Value Pathway (MVP) as a subgroup will inherit any reweighting approved for their affiliated group. Alternative Payment Model (APM) Entities may submit an application but are required to request reweighting for all performance categories.

Apply for a MIPS EUC Exception

The MIPS EUC Exception application for the 2025 performance year will be available until  8 p.m. ET on December 31, 2025. If you’ve been affected by an extreme and uncontrollable circumstance, you can apply for this exception whether reporting traditional MIPS, an MVP, or the APM Performance Pathway (APP).

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), and/or;
• Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.

Application Process

You'll need a Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) account to submit a MIPS EUC Exception application. Once you sign in to QPP with your HARP credentials, click "Exceptions Application" on the left-hand navigation and then select "Extreme and Uncontrollable Circumstances."

For more information on how to obtain a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide (ZIP, 3MB).  

The MIPS EUC Exception application deadline is 8 p.m. ET on December 31, 2025.

Application Status

You'll be notified via email if your request was approved or denied. You can also check the status of your application by signing in to the QPP website. If approved, this approval will be added to your eligibility profile in the QPP Participation Status Tool on a rolling basis. If your application is approved at the end of the performance year, it may not appear in the QPP Participation Status Tool until the submission window opens in 2026.

If your application is approved, you don’t have to report for the requested MIPS performance category or categories, and those categories will be reweighted.

You Can Still Submit Data

Whether you qualify for automatic reweighting or have an approved exception application, you can still report data. We’ll score any qualifying submission, and the performance categories for which you submitted data will contribute to your final score. (Note that there’s no data submission associated with the cost performance category so you can’t override cost reweighting.) 

Example: You’re approved for reweighting in all 4 performance categories but later determine you can collect and report data for the Promoting Interoperability and improvement activities performance categories. Data submission for these 2 performance categories won’t affect the quality and cost performance categories which will still be weighted at 0% of your final score.

APM Entities Exception Application

APM Entities participating in MIPS APMs can submit a MIPS EUC Exception application with some differences from our existing policy for individuals, groups, and virtual groups:

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

You'll be notified via email if your request was approved or denied. You can also check the status of your application by signing in to the QPP website. If approved, this approval will be added to your eligibility profile in the QPP Participation Status Tool on a rolling basis. If your application is approved at the end of the performance year, it may not appear in the QPP Participation Status Tool until the submission window opens in 2026.

Automatic EUC Exception

MIPS eligible clinicians who are located in a Centers for Medicare & Medicaid Services (CMS)-designated region that has been affected by an extreme and uncontrollable circumstances event (such as a Federal Emergency Management Agency-designated major disaster) during the 2025 performance year, receive the automatic EUC exception. We identify qualifying events through the QPP Listserv (you can subscribe at the bottom of any page on the website).

• The automatic EUC policy doesn't apply to group, virtual group, or APM Entity participation.

MIPS eligible clinicians in a county affected by the event will have all 4 MIPS performance categories reweighted to 0% of their final score unless they submit data for 2 or more performance categories.

• These clinicians are automatically identified and don’t need to submit an exception application.

If you qualify for the automatic exception and have an approved exception application, the performance category reweighting from the automatic exception will supersede any performance category reweighting approved through the application.

MIPS Promoting Interoperability Performance Category Hardship Exception

Apply for a MIPS Promoting Interoperability Hardship Exception

The MIPS Promoting Interoperability Performance Category Hardship Exception application deadline is 8 p.m. ET on December 31, 2025. Clinicians, groups, and virtual groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception application whether reporting traditional MIPS, an MVP, or the APP. 

• This application isn’t available to APM Entities. 

Hardship exceptions are available for the following specified reasons:

• You have decertified EHR technology (must be decertified under the Office of the National Coordinator for Health Information Technology’s (ONC) Health IT Certification Program).
• 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 CEHRT.

Simply lacking the required CEHRT doesn't qualify you for reweighting.

NOTE: If you're already exempt from submitting Promoting Interoperability data, you don't need to apply for this application. Learn more. 

Application Process 

You'll need a HCQIS Access Roles and Profile (HARP) account to submit a MIPS Promoting Interoperability Performance Category Hardship Exception application. Once you sign in to the QPP website with your HARP credentials, select "Exceptions Application" on the left-hand navigation and then select "Promoting Interoperability Hardship." 

For more information on how to obtain a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide (ZIP, 3MB).  

The MIPS Promoting Interoperability Hardship Exception application deadline is 8 p.m. ET on December 31, 2025.

Application Status

You'll be notified via email if your request was approved or denied. You'll also be able to check the status of your application by signing in to the QPP website. If approved, this approval will be added to your eligibility profile in the QPP Participation Status Tool on a rolling basis. If your application is approved at the end of the performance year, it may not appear in the QPP Participation Status Tool until the submission window opens in 2026.

If your application is approved, you don't have to report for the MIPS Promoting Interoperability performance category, and the category will be reweighted to 0% of your final score.

The Promoting Interoperability performance category weight will be redistributed to another performance category (or categories) unless you choose to submit data. If you submit data, the hardship will be cancelled, and your data will be scored.

You Can Still Submit Data

Whether you qualify for automatic reweighting or have an approved exception application, you can still choose to report. A qualifying submission (all required measures and attestations) will override your approved exception application. We’ll score your data, and the Promoting Interoperability performance category will count towards your MIPS final score.

MIPS APM Participants

Clinicians (and groups with clinicians) participating in a MIPS APM can apply for hardship exceptions and qualify for automatic reweighting just like other MIPS eligible clinicians. If you’re participating in MIPS at the APM Entity level (either reporting traditional MIPS, MVPs, or the APP), you'll receive the APM Entity’s score but will be excluded from the calculation when we create an average Promoting Interoperability score for the APM Entity. There will be an example of this calculation in the 2025 APM Performance Pathway Scoring Guide, which will be available on the QPP Resource Library later in 2025.

Medicare Shared Savings Program Participants

Unless excluded, for performance years beginning on or after January 1, 2025, an ACO participant, ACO provider/supplier, and ACO professional that is a MIPS eligible clinician, Qualifying APM Participant (QP), or Partial Qualifying APM Participant (Partial QP) must: 

• Report the MIPS Promoting Interoperability performance category measures and requirements to MIPS at the individual, group, virtual group, or APM Entity level (i.e., ACO reports on behalf of its clinicians); and
• Earn a performance category score for the MIPS Promoting Interoperability performance category at the individual, group, virtual group, or APM Entity level.

These ACO participants, ACO providers/suppliers, and ACO professionals can apply for hardship exceptions and qualify for automatic reweighting just like other MIPS eligible clinicians.

Automatic Reweighting for Promoting Interoperability

We automatically reweight the Promoting Interoperability performance category for certain clinicians, groups, virtual groups, and APM Entities based on clinician type and special status. If this performance category is reweighted, you don’t need to collect or submit Promoting Interoperability data if you qualify for one of the special statuses below:  

• Ambulatory surgical center (ASC)-based;
• Hospital-based; 
• Non-patient-facing; and 
• Small practice. 

NOTE: Small practice is the only special status available to APM Entities.

If you’re reporting as a group or virtual group, all MIPS eligible clinicians in the group or virtual group must qualify for reweighting for the group to be reweighted, unless the group or virtual group has a special status that qualifies them for automatic reweighting.