2025 MIPS Hardship Application Deadline Approaching

The deadline to file for a 2025 MIPS hardship is rapidly approaching. The Centers for Medicare and Medicaid Services (CMS) requires 2025 MIPS hardship applications to be submitted by December 31, 2025, at 8 pm ET.

There are two applications available, the Extreme and Uncontrollable Circumstance (EUC) hardship application and the Promoting Interoperability (PI) exception application. Both applications are available in your QPP account.

If you were affected by the Los Angeles wildfires or Texas flooding this year, you may be eligible for an automatic hardship. Take a look at the eligible counties and read important notes about the automatic hardship in our previous blog.

Factors CMS Considers in Hardship Applications

CMS reviews applications taking into account both the event circumstances (what happened) and the timing (how long the circumstances impacted you) to assess your ability to collect and/or submit data for each performance category selected in the application.

• For the Cost and Quality category exceptions, CMS generally expects the circumstance to have lasted for at least 3 months.
  • For example, a natural disaster or ransomware attack that prevented you from collecting Quality data for 3 or more months.
• Because the Improvement Activities (IA) and PI categories have shorter performance periods (90 days and 180 days, respectively), CMS expects the circumstances affecting performance or preventing performance in those categories to be more prolonged.
  • For example, if you switch EHR vendors during the performance period, you may claim a PI hardship for vendor issues.

Reweighting Scenarios

Steps to Apply

If you are an Anatomy IT client, contact your MIPS Expert to complete this process for you; otherwise:

1. Sign in to your QPP account.
2. Select “Exception Applications” on the left-hand navigation.
3. Select “Add New QPP Exception.”
4. Select either “MIPS Promoting Interoperability Performance Category Hardship Exception” or “Extreme and Uncontrollable Circumstances Exception.”
5. Complete the application at either the individual, group, virtual group, or APM Entity participation level.
   • 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.
   • Note for APM Entities: APM Entities can submit applications as well, but they must apply for all performance categories and at least 75% of the MIPS eligible clinicians in the Entity will need to qualify for reweighting in PI.
   • Note for MVP Subgroup Reporters: Clinicians who register to report an MVP as a subgroup will inherit the performance category reweighting approved for their affiliated group. Subgroups cannot request reweighting independent of their affiliated group’s status.
   • Follow these links for more information on PI Hardship Applications (PDF) and 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

• Deadline: Submit hardship applications by December 31, 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.
• What if you submit data? If you submit data on a category you have an approved hardship for, the data submission will override that category’s hardship and that category will be scored.
  • If you were approved for an EUC for all 4 MIPS performance categories, you will only receive a MIPS final score if you submit data on 2 or more performance categories. You will only be scored on the categories you submit data on in this circumstance.
• Automatic category scoring in certain circumstances: 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).
• MVP subgroup reporters:
  • Your MVP subgroup will inherit the category hardship(s) approved for your affiliated group. Subgroups cannot request reweighting independent of their affiliated group.
  • If the affiliated group submits data: Only the affiliated group will be scored. It will not override the hardship(s) for the subgroup. Your subgroup will continue to receive the hardship(s) approved for the MVP group.
  • If your MVP subgroup submits data: the data submission will override that category’s hardship and that category will be scored for your subgroup only. The affiliated group’s hardship(s) will not be impacted by your subgroup’s submission.
• What if you notice a mistake in your application?
  • Contact the QPP Service Center by email at QPP@cms.hhs.gov, by creating a QPP Service Center ticket, or by phone at 1-866-288-8292 (Monday-Friday, 8 am – 8 pm ET).
• 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 2025 MIPS final score and 2027 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 2025 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

• If you need to apply for a hardship, make sure to submit your application before December 31, 2025, at 8 pm ET.
• 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.
• 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!

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Written By: Sarrah Hakim, MHSA

About the Author: Sarrah is the Director of Health Policy at Anatomy IT.