Sometimes things happen that are completely out of your control. Natural disasters hit. Computer systems crash. Cyberattacks shut down your operations. When these events prevent you from completing MIPS reporting, CMS offers relief through hardship exceptions.
Applying for MIPS hardship exceptions protects your practice from unfair penalties. Even when circumstances beyond your control disrupt your ability to collect or submit performance data. These exceptions can save you from losing thousands of dollars in Medicare payments when legitimate problems prevent normal reporting.
We helps practices navigate these applications when unexpected events interfere with their MIPS obligations. Understanding your options and meeting the deadlines makes the difference between getting relief and facing penalties you don’t deserve.
Two Types of Relief Available
CMS provides two different pathways for practices facing reporting difficulties. Each one addresses different types of problems.
- The Extreme and Uncontrollable Circumstances Exception covers major disruptions that affect your entire operation. Natural disasters, fires, floods, cyberattacks, and extended power outages qualify. This exception applies to individual clinicians, groups, virtual groups, and APM entities.
- The Promoting Interoperability Hardship Exception focuses specifically on EHR-related problems. This applies when your electronic health record vendor loses certification, your internet connectivity is insufficient, or you lack control over the certified technology your practice uses.
You can apply for both exceptions at the same time if your situation meets the criteria for each. Some events might qualify under both categories depending on how they impact your practice.
Filing Deadlines You Cannot Miss
The application window for both exceptions closes on December 31, 2026, at 8 PM Eastern Time. This is a hard deadline. Late applications get rejected regardless of your circumstances.
These exceptions apply to the 2026 performance period, which runs from January 1 through December 31, 2026. The relief you receive affects your 2028 payment adjustments. Remember that MIPS always works two years out.
Don’t wait until December to file. CMS reviews applications on a rolling basis throughout the year. Applying early gives you more time to address any issues with your application and ensures you meet the deadline.
Extreme and Uncontrollable Circumstances Exception Details
This exception allows CMS to reweight one or more of your performance categories to 0%. The categories include Quality, Cost, Promoting Interoperability, and Improvement Activities.
When a category gets reweighted to 0%, it doesn’t count toward your final score. The remaining categories make up 100% of your score instead. This prevents disasters and major disruptions from destroying your overall performance rating.
Events that qualify include natural disasters like hurricanes, tornadoes, earthquakes, and wildfires. System-wide outages, vendor issues that affect all clients, and cyberattacks also qualify. The key is that the event must be beyond your reasonable control and must significantly impact your ability to report.
APM entities face a special requirement. They must request reweighting for all performance categories, not just select ones. This all-or-nothing approach applies only to APM participants.
CMS expanded this exception in 2026 to include cost and administrative claims-based measures. Previous versions focused mainly on EHR and quality data. Now CMS recognizes that disasters affect billing and claims processing too.
Promoting Interoperability Hardship Exception Specifics
This exception reweights only the Promoting Interoperability category to 0%. It addresses technical and vendor-related problems that prevent EHR reporting.
Common reasons include EHR vendor decertification, insufficient internet bandwidth, lack of control over certified technology, and new practices still implementing systems. Small practices with limited patient volumes may also qualify.
When this category gets reweighted, the remaining three categories increase proportionally to make up your full score. Quality, Cost, and Improvement Activities together equal 100% of your final score.
This exception targets situations where the technology itself creates the barrier, not general operational disruptions. If a natural disaster damages your servers, that falls under EUC. If your vendor loses certification through no fault of yours, that’s a PI Hardship.
Automatic Relief for Disaster Areas
CMS automatically grants EUC relief to clinicians in federally designated disaster areas. You don’t need to apply to receive this benefit.
For example, providers affected by the 2026 California wildfires automatically qualified for relief. CMS identified these providers based on their practice location and the federal disaster designation.
There’s an important catch. If you submit data in two or more categories, you override the automatic exception. CMS assumes you can report if you’re submitting data. Only submit data if you want to be scored normally.
Check the CMS website to see if your location qualifies for automatic relief. This saves you the application process and ensures you get protection immediately.
Steps for Applying for MIPS Hardship Exceptions
- Log in to the Quality Payment Program portal at qpp.cms.gov. Navigate to the Exception Applications section. This is where you submit both types of exceptions.
- Choose which exception applies to your situation. You can select EUC, PI Hardship, or both if your circumstances qualify for multiple exceptions.
- Describe the event that prevented normal reporting. Be specific. Include dates, nature of the disruption, and how it affected your data collection or submission. Vague descriptions lead to denials.
- Provide supporting documentation. Save closure notices, vendor communications, disaster declarations, and outage reports. CMS may request this evidence to verify your claim.
- For APM entities, remember to request reweighting for all categories. Partial requests get denied for APM participants.
- Submit your application and save the confirmation. CMS reviews applications and notifies you of their decision through the portal.
What Happens After Approval
Once CMS approves your exception, the affected categories get reweighted to 0%. They no longer factor into your score calculation.
Do not submit data for approved categories. Submitting data overrides your exception and triggers normal scoring. Many practices make this mistake and lose their relief.
If you receive PI Hardship approval, don’t submit any Promoting Interoperability data. If you get EUC approval for Quality and PI, don’t submit data for either category. Only submit data for categories not covered by your exception.
Your final score gets calculated using only the categories that weren’t reweighted. If you had three categories at 0%, your remaining category makes up your entire score.
What is the Required Documentation
Keep detailed records of any events that might qualify for exceptions. Store these records for at least six years per CMS requirements.
Save copies of all vendor communications about outages, decertifications, or system problems. Print disaster declarations from FEMA or state emergency management agencies. Document the dates your practice closed or couldn’t access systems.
Take screenshots of error messages, system outages, and vendor notices. These provide concrete evidence of the problems you faced.
Create a timeline showing when the disruption started, how long it lasted, and when normal operations resumed. This helps CMS understand the scope and duration of your problem.
Good documentation makes approvals easier and protects you if CMS questions your exception later.
Common Mistakes to Avoid
Missing the December 31 deadline is the biggest error. Set calendar reminders well in advance. Don’t assume you have extra time.
Submitting vague applications without specific details leads to denials. Explain your situation clearly with dates and concrete information.
Failing to save supporting documentation creates problems when CMS requests verification. Collect evidence as events happen, not months later when you file.
Submitting data for reweighted categories cancels your exception. Make sure your entire team knows which categories are covered by exceptions before any data submission occurs.
Applying for the wrong exception type wastes time. EUC covers broad operational disruptions. PI Hardship covers specific EHR and technology issues. Choose the right one for your situation.
Coordinating With Your Team
Notify everyone involved in MIPS reporting services about your exception application. Your EHR staff, quality team, and billing department all need to know.
Create a clear list of which categories are covered by exceptions and which require normal reporting. Post this information where your reporting team can reference it easily.
Establish a verification process before submitting any MIPS data. Have someone check that you’re not accidentally submitting information for reweighted categories.
If you work with a MIPS registry or reporting partner, inform them immediately about your exception application. They need to adjust their submission plans accordingly.
We coordinates these communications for our clients to ensure everyone stays aligned throughout the exception period.
Why Early Application Matters
CMS processes applications throughout the year on a rolling basis. Early submissions get reviewed faster and give you time to address any issues.
Waiting until December creates stress and leaves no room for error. If CMS requests additional information or clarification, you need time to respond before the deadline.
Some events require time to fully document. A cyberattack investigation might take weeks. Getting your application started early ensures you capture all necessary information while it’s fresh.
Applications filed months in advance also demonstrate good faith effort to comply with requirements despite difficult circumstances.
Getting Professional Help
The exception application process involves specific requirements and technical details. Working with specialists who understand MIPS regulations prevents costly mistakes.
Prime Well Med Solutions assists practices with exception applications from start to finish. We know which documentation CMS requires, how to describe events effectively, and how to avoid common application errors.
Professional guidance costs far less than the penalties you face without proper exception approval. A denied application means full MIPS scoring applies, including potential payment reductions.
We also track your exception status and ensure you don’t accidentally submit data for reweighted categories after approval.
Planning for Future Performance Years
Applying for MIPS hardship exceptions addresses immediate problems, but you still need long-term solutions. Use the relief period to fix underlying issues.
If vendor problems caused your hardship, consider switching to more reliable systems. If internet connectivity created barriers, explore better service options or backup connections.
Document lessons learned from the disruption. What systems failed? What backup procedures would have helped? Use this information to strengthen your operations for future reporting periods.
Build contingency plans for common disruptions. Having procedures in place for power outages, system failures, and natural disasters helps you maintain reporting even during difficult circumstances.
Taking Action Now
Applying for MIPS hardship exceptions provides essential protection when legitimate problems prevent normal MIPS & MVP reporting. Know your deadlines, understand which exception fits your situation, and document everything thoroughly.
Don’t wait for disaster to strike before learning about these options. Familiarize yourself with the requirements now so you’re prepared if problems arise. Keep good records throughout the year so you have evidence ready if needed.
If you’re currently facing circumstances that prevent proper MIPS reporting, file your application as soon as possible. The December 31 deadline arrives faster than you think, and early applications have better success rates.
Your practice deserves fair treatment when circumstances beyond your control disrupt operations. These exceptions exist to protect providers from unfair penalties. Use them when appropriate and protect your Medicare revenue from unjust reductions.
You May Need to Read:
Four Ways Clinicians Can Qualify for CMS MIPS Exceptions
Understanding the 2026 Medicare Physician Updates for Your Practice
5 MIPS Confusing Parts That Trip Up Healthcare Providers And How to Fix Them
