Due to the ongoing impacts of the COVID-19 public health emergency, the Centers for Medicare & Medicaid Services (CMS) has announced it will continue to allow physicians and group practices to apply for a MIPS Extreme and Uncontrollable Circumstances (EUC) hardship exception to avoid up to a -9% MIPS penalty in 2025 based on 2023 performance.
 
This exception will not be automatic: interested physicians and groups must actively request reweighting of one or more MIPS performance categories due to the COVID-19 public health emergency. Requesting reweighting of all four MIPS performance categories will avoid a MIPS penalty in 2025. 
 
CMS expects to release the hardship exception application in spring 2023. 
 
The American Medical Association and other organized medicine advocated for this decision.

CMS estimated in the final rule that up to one-third of MIPS-eligible clinicians would have received a penalty due to the stringent requirements to participate in MIPS in 2023. According to the AMA, small, rural and practices serving underserved populations would likely have been disproportionately impacted by these penalties.
 
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