In Response to COVID-19, CMS Announces Relief for MIPS-Eligible Clinicians in 2020

Last Updated: Jul 7, 2020

keyboard-stethoscopeThe Centers for Medicare and Medicaid Services (CMS) will accept Extreme & Uncontrollable Circumstances applications for Merit-based Incentive Payment System (MIPS) eligible clinicians who have been significantly affected by the COVID-19 emergency during the 2020 performance year.

Here’s a closer look at the exception opportunities available for MIPS in 2020.

About the Extreme & Uncontrollable Circumstances Hardship Exception

CMS defines Extreme & Uncontrollable Circumstances as events outside of a clinician’s or practice’s control that would:

  • Cause you to be unable to collect information necessary to submit for a MIPS performance category;
  • Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the Quality performance category for 3 months), and/or;
  • Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.

Applicants can request a reweighting of any or all MIPS performance categories and will be required to include a justification for how their practice has been significantly impacted by the public health emergency.

An HCQIS Access Roles and Profile (HARP) account is required for the Extreme and Uncontrollable Circumstances Application. Once you sign into Quality Payment Program website at with your credentials, click ‘Exceptions Application’ on the left-hand navigation and then select ‘Extreme and Uncontrollable Circumstances.’

The deadline to apply is Dec. 31, 2020. Applicants will be notified via email about whether their request was approved or denied.

MIPS Promoting Interoperability Performance Category Hardship Exception

If you are participating in MIPS during the 2019 performance year as an individual, group, or virtual group – or participating in a MIPS Alternative Payment Model (APM) – you can submit a Promoting Interoperability hardship exception application for one of the following reasons:

  • You are a small practice
  • You have decertified EHR Technology
  • You have insufficient internet connectivity
  • You face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
  • You lack control over CEHRT availability

Applicants are required to have a HARP account. Once you sign into QPP with your credentials, select ‘Exceptions Application’ on the left-hand navigation and then select ‘Promoting Interoperability Hardship.”

The deadline to apply is Dec. 31, 2020. Applicants will be notified via email about whether their request was approved or denied.

Important Note: Some clinicians may be exempt from the Promoting Interoperability category – hospital-based clinicians, for example – and will be automatically be reweighted based on their special status. Those clinicians do not need to submit a hardship exception application.

If you’re not sure whether you’re required to participate in the QPP this year or whether you are automatically exempt from Promoting Interoperability participation, you can find out using the Centers for Medicare and Medicaid Services’ (CMS) Participation Status Tool.

Additional Resources

CMS' Quality Payment Program website offers resources on hardship exceptions, including a QPP exceptions webpage here.

You can find PAMED’s Quick Consult fact sheets on the Quality Payment Program here.

Pennsylvania Medical Society (PAMED) members with questions on participating in the QPP by contacting our Knowledge Center at (855) 726-3348 or

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