New 2025 MIPS Automatic Hardships Announced!

Important Notes for Those in the Identified Areas

• 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 the announcement of the automatic EUC, will be scored at the individual level on Quality (1 MIPS category).
• The Automatic EUC applies only to individual MIPS eligible clinicians. It does not apply to groups, virtual groups, or APMs.
  • If you are part of an APM Entity: You will receive a MIPS Final Score and payment adjustment associated with the higher of your individual or APM Entity scores.
  • Group reporting is optional. If you have not reported and do not report any 2025 MIPS data at the group level, your clinicians will only be evaluated at the individual level (and have the automatic EUC applied).
    • You can still report on the individual level, if you would like.
    • If you group report and you do not exceed the low-volume threshold at the individual level, you will only receive the group score.
  • All individual MIPS eligible clinicians who receive an automatic EUC exception will have Cost reweighted, regardless of whether they choose to report other performance categories.
• 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.
    • Reminder: Clinicians in APMs are automatically scored on Improvement Activities and clinicians who have submitted quality data codes on Medicare Part B claims at any point in 2025 will receive a Quality category score. If a clinician is both in an APM and has submitted any 2025 quality data codes on Medicare Part B claims, they will automatically have 2 MIPS categories scored.
  • If you submit data on 1 or fewer MIPS categories, 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

• 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 Client Success Manager if you have any questions or if you plan on using this automatic hardship. Your Client Success Manager 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!

Written By: Jessica Peterson, MD, MPH

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