2024 MIPS Submission Deadline Extended and New Available Hardship!

March 25, 2025

The Centers for Medicare and Medicaid Services (CMS) has extended the 2024 MIPS submission to April 14, 2025, at 8 pm ET. This is in response to the ongoing IV fluid shortage and to provide relief to impacted practices.

Note: If you are not required to report but are opting in (Partial QPs and practices that exceed some, but not all, low-volume thresholds), the deadline is not extended and remains March 31, 2025, at 8 pm ET.

2024 Extreme and Uncontrollable Circumstance (EUC) Application Reopened for IV Fluid Shortage

CMS has also announced that they will reopen the EUC hardship application, but only for practices requesting an EUC due to hardships caused by the IV fluid shortage. Any applications submitted for reasons outside of the national IV fluid shortage will be denied.

An example of a qualifying hardship would be if your practice’s administrative and support staff has needed to focus on supply chains to support patients’ care, affecting their capacity to collect and prepare data for reporting. Another example could potentially include practices that had to ration IV fluids amid the shortage, which could negatively affect certain MIPS quality and cost measures.

The EUC hardship application will be available through your QPP account from March 31, 2025 (10 am ET) – April 14, 2025 (8 pm ET).

Remember that, even if your EUC is approved, it won’t override any data you have submitted.

Reweighting Scenarios

Steps to Apply

If you are an Anatomy IT client, contact your MIPS Expert to complete this process for you. CMS has not yet released the IV Fluid Shortage EUC application, but the steps are expected to be consistent with the general EUC application process, which is as follows:

  1. Sign in to your QPP account.
  2. Select “Exception Applications” on the left-hand navigation.
  3. Select “Add New QPP Exception.”
  4. Select “Extreme and Uncontrollable Circumstances Exception.”
  5. Complete the application at either the individual, group, virtual group, or APM Entity participation level.
    1. Note: you must complete the hardship application at the level for which you will report data to MIPS. Group applications will not apply to individual reporters and vice versa.
    2. Follow these links for more information on EUC Hardship Applications (PDF).
  6. After you submit your application, you will receive a message and an email stating that your application has been successfully submitted and is pending review.
  7. Once your application has been reviewed and a decision has been made, CMS will post the decision to your QPP account. You can also monitor your application status from there.

Important Notes

  • New 2024 MIPS Submission Deadline: April 14, 2025 at 8 pm ET.
  • EUC Hardship Application for IV Fluid Shortage Impact Available: March 31, 2025 at 10 am ET – April 14, 2025 at 8 pm ET.
  • Retain documentation of the hardship for at least six years in case of an audit.
  • Hardships from previous years do not carry forward. You must submit a new application each year in which you experience a hardship.
  • Clinicians might be automatically scored on certain categories in the following circumstances:
    • Clinicians in APMs automatically receive Improvement Activities credit and so are automatically scored on at least 1 MIPS category.
    • Submitting Quality Data Codes on Medicare Part B Claims: clinicians/groups submitting quality data codes on claims, even if only submitted prior to applying for a hardship, will be scored at the individual level on Quality (1 MIPS category).
  • If you are granted a hardship:
    • Do not submit data in the categories for which you received a hardship exception or CMS will score those categories.
    • If you submit data on 2+ MIPS categories, CMS will score you on the reported categories and assign you a 2024 MIPS final score and 2026 payment adjustment.
    • If you submit data on 1 or fewer MIPS categories (such as small practice claims-based Quality reporters), CMS will assign you a 2024 MIPS score equal to the threshold to avoid a penalty.
    • If you get a hardship for all categories, CMS will assign you a score equal to the threshold to avoid a penalty.

Next Steps

  • Share this information with your colleagues.
  • Subscribe to our blog to get alerts on this and other important issues. You can subscribe using the field in our website footer below.
  • If you are an Anatomy IT client:
    • Contact your MIPS Expert if you have any questions or if you plan on applying for a hardship. Your MIPS Expert will help you evaluate your eligibility and retain the necessary documentation on your behalf.
  • If you are not an Anatomy IT client:
    • Contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.

If you have any questions on this, let us know!

Jessica Peterson, MD, MPHWritten By: Jessica Peterson, MD, MPH

About the Author: Jessica Peterson, MD, MPH is the Senior Director of Value-Based Care Policy at Anatomy IT.

Posted in MIPS, blog