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Policy Snapshot

December 2, 2024

The 2024 Quality Payment Program (QPP) Exception applications are available through December 31, 2024, at 8:00 PM ET. Two types of exception applications allow users to indicate the reason they’re unable to report data for one or more Merit-based Incentive Payment System (MIPS) performance categories. 

MIPS Promoting Interoperability Performance Category Hardship Exception Application

Individual clinicians, groups, and virtual groups (or a third-party representative) can submit a MIPS Promoting Interoperability Performance Category Hardship Exception application for the following reasons:

  • You have decertified Electronic Health Record (EHR) technology (must be decertified under the Office of the National Coordinator for Health Information Technology’s [ONC] Health IT Certification Program).  
  • You have insufficient internet connectivity.  
  • You face extreme and uncontrollable circumstances such as a disaster, practice closure, severe financial distress, or vendor issues.  
  • You lack control over the availability of certified EHR technology (CEHRT).  

This application is specific to the MIPS Promoting Interoperability performance category. If your application is approved, you won’t be required to report data for this performance category.

MIPS Extreme and Uncontrollable Circumstances Exception Application

Individual clinicians, groups, and virtual groups (or a third-party representative) can submit a MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application for one or more MIPS performance categories (quality, cost, improvement activities, and promoting interoperability) due to extreme and uncontrollable circumstances, defined as rare events entirely outside of your control and the control of the facility in which you practice.

These circumstances 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).  
  • Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.  

Alternate Payment Model (APM) Entities can submit applications as well, but they must apply for all performance categories.

If your application is approved, you won’t be required to report data for the performance category or categories included in your approved application. However, please note that data submission overrides approved reweighting on a category-by-category basis. The QPP Program will score any data you, or someone on your behalf, submits and those performance categories will contribute to your final score.

How to Apply

To submit either exception application:

  • Sign in to the QPP website with your Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) account.  
  • Choose “Exceptions Application” from the left-hand navigation.  
  • Click on “Add New QPP Exception” on the right side of the screen.  
  • Choose your exception type.  

Additional Resources