CMS Accepting Applications for Hardship and Extreme and Uncontrollable Circumstances MIPS Exceptions

The Center for Medicare and Medicaid Services (CMS) is accepting hardship exception applications for the Promoting Interoperability (PI) Performance Category, 2019 Performance Year of the Merit-based Incentive Payment System (MIPS). Providers who qualify can have their PI performance category reweighted to 0%. MIPS participating clinicians and groups can request a hardship exception for the following reasons: MIPS-eligible clinicians in small practices, MIPS-eligible clinicians using decertified EHR technology, insufficient internet connectivity, lack of control over the availability of CEHRT, and extreme and uncontrollable circumstances. The application for PI hardship exception is available here.

Additionally, CMS is also accepting applications from MIPS-eligible clinicians who experienced an extreme and uncontrollable circumstance during the 2019 MIPS Performance Year. “Extreme and uncontrollable circumstances” are defined as rare events (highly unlikely to occur in a given year) entirely outside of the participating clinician’s control and the facility in which they practice. MIPS clinicians who are identified as being impacted by an extreme and uncontrollable event will have all four performance categories (Quality, Cost, Improvement Activities and Promoting Interoperability) reweighted to 0%. The application for extreme and uncontrollable exceptions is available here.

Both applications are open for the remainder of the 2019 Performance Year, closing on December 31, 2019. More information about both MIPS exceptions can be found here.


For more information visit the McDermottPlus Payment Innovation Resource Center or contact Sheila Madhani at 202-204-1459 or