Appendix I 2025 MIPS Extreme and Uncontrollable Circumstances Excep

OMB control number: 0938-1314
Expiration Date: 02/28/2027

Merit-based Incentive
Payment System (MIPS)
2025 Extreme and Uncontrollable
Circumstances Exception Application
Guide

Table of Contents
How To Use This Guide

3

Overview

5

Frequently Asked Questions

13

Application Steps

17

Help and Version History

30

Appendices

33

Purpose: This guide will provide
general information about the
Extreme and Uncontrollable
Circumstances (EUC) Exception
application and provide step-by-step
instructions on how to complete the
application.

Already know what MIPS is? Skip
ahead by clicking the links in the Table
of Contents.

2

How to Use This
Guide

OVERVIEW

How to Use This Guide

Table of Contents
Please Note: This guide was prepared for
informational purposes only and isn't intended
to grant rights or impose obligations. The
information provided is only intended to be a
general summary. It isn't intended to take the
place of the written law, including the
regulations. We encourage readers to review the
specific statutes, regulations, and other
interpretive materials for a full and accurate
statement of their contents.

The Table of Contents is interactive. Click on a
Chapter in the Table of Contents to read that
section.
You can also click on the icon on
the bottom left to go back to the Table of
Contents.

Hyperlinks
Hyperlinks to the Quality Payment Program
website are included throughout the guide
to direct the reader to more information and
resources.

4

MIPS Extreme and
Uncontrollable
Circumstances Exception
Application Overview

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Overview
We understand that there may be circumstances out of your control that make it difficult for you to meet program requirements. To reduce
this burden, we provide an opportunity for clinicians, groups, virtual groups and Alternative Payment Model (APM) Entities to apply and
request performance category reweighting for MIPS.
The MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application allows you to request reweighting for one or more performance categories to 0%.

What

Who

Why

See Appendix A1, Appendix A2, and Appendix B for more information on performance category reweighting in traditional MIPS, MIPS Value Pathways (MVPs) and
the APM Performance Pathway (APP).
Individual clinicians, groups, virtual groups, and APM Entities.
• Third party intermediaries can submit an application with permission from the clinician or practice.
Subgroups will inherit any reweighting applied to their affiliated group; they can't request reweighting independent of their affiliated group's status. See Slide 11 for
additional information.
You can submit an application to have your MIPS quality, cost, improvement activities, and/or Promoting Interoperability performance categories reweighted to 0%
if:
• You experience an extreme and uncontrollable circumstance outside of your control, such as a natural disaster, ransomware attack or public health emergency
(PHE), that prevents you from collecting data for an extended period of time, or that could impact your performance on cost measures.
The 2019 Coronavirus (COVID-19) PHE ended on May 11, 2023. We're not accepting applications due to COVID-19 for the 2025 performance year.
Note: APM Entities are required to request reweighting for all performance categories.

When

The MIPS EUC Exception application will close on December 31, 2025, at 8 p.m. ET.
Sign in to the Quality Payment Program (QPP) website with your HCQIS Access and Roles Profile (HARP) account.

Where

How

You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application. For more information on HARP accounts, please
refer to the Register for a HARP Account document in the QPP Access User Guide (ZIP, 4MB).
Note: APM Entity representatives must have the Security Official role in order to complete the Extreme and Uncontrollable Circumstances Exception application on
behalf of their entity. Refer to the Connect to an Organization document in the QPP Access User Guide (ZIP, 4MB) for more information on requesting the Security
Official role.
4. Select 'Add New Exception.'
1. Register for a HARP account.
5. Select 'Extreme and Uncontrollable Circumstances Exception.'
2. Sign in to the QPP website.
6. Complete the application for individual, group, virtual group, or APM Entity
3. Select 'Exceptions Applications' on the left-hand navigation.
participation.

6

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Policies for Individual Clinicians, Groups, and Virtual Groups
MIPS EUC Exception applications can be submitted for one or
more performance categories. Any qualifying data you, or
someone on your behalf, submits will override approved
reweighting for that performance category and the category will
be scored.
• A qualifying data submission voids the 0% performance
category weight on a category-by-category basis; a nonqualifying (incomplete) submission for a performance
category won't void its 0% weighting. See Appendix D for
more information.
• If you later determine that you're able to collect data for a
performance category approved in your application, you can
submit that data and it will be scored.
• If the cost performance category is included in your
application, cost measures won't be scored even if data is
submitted for other performance categories.
• If you submit Medicare Part B Claims measures during the
performance year, this will override quality performance
category reweighting. However, if you request and are
approved for reweighting in all 4 performance categories and
don't submit data for another performance category, your
MIPS final score for the 2025 MIPS performance period would
be equal to the performance threshold and you would receive
a neutral payment adjustment in 2027.

You must be scored on at least 2 performance categories to
earn a MIPS final score other than the performance threshold.
• When fewer than 2 performance categories can be scored
(meaning 1 performance category is weighted at 100% of
your MIPS final score, and the other performance
categories are weighted at 0%), the MIPS final score for
the 2025 MIPS performance period would be equal to the
performance threshold and you would receive a neutral
payment adjustment in 2027.
You'll be scored in any performance category that's not included in
your application, unless you qualify for reweighting through another
policy.
For example:
• If you don't meet the case minimum for any cost measures, the
cost performance category will be reweighted.
• You qualify for reweighting under the automatic Extreme and
Controllable Circumstances policy.
◦ Review the 2025 Automatic Extreme and Uncontrollable
Circumstances Fact Sheet (PDF, 334KB) for additional
information.
• Certain clinician types and individuals, groups, and virtual groups
with certain special statuses qualify for automatic reweighting of
the Promoting Interoperability performance category.
◦ For additional information on automatic reweighting of
Promoting Interoperability, review the 2025 Promoting
Interoperability Quick Start Guide (PDF, 849KB).

7

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Intersection Between the Automatic MIPS EUC Policy and the
Application-Based MIPS EUC Policy
If you qualify for reweighting under the automatic MIPS EUC policy, then we'll reweight all 4 performance categories to 0% (rather
than just the categories included in your MIPS EUC Exception application). We'll score any performance category for which
qualifying data is submitted.

Example
Scenario

Outcome
You'll be scored as follows:

A MIPS eligible clinician who is eligible for the automatic
MIPS EUC policy has also submitted an MIPS EUC
Exception application. The application was approved for
reweighting in the Promoting Interoperability
performance category, and the clinician submits
qualifying data for the quality and improvement activities
performance categories.

• The quality and improvement activities performance
categories will be scored because you submitted
qualifying data for those categories.
• The cost performance category is reweighted to 0%
under the automatic EUC policy.
• The Promoting Interoperability performance category
is also reweighted to 0% under the automatic EUC
policy.
Note: in this example, the MIPS EUC Exception
application wasn't needed to reweight the Promoting
Interoperability performance category due to the
automatic MIPS EUC policy.

8

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Individual Clinicians, Groups, and Virtual Groups Reporting Traditional
MIPS / Individual Clinicians and Groups Reporting an MVP
If you qualify for reweighting under the automatic MIPS EUC policy, then we'll reweight all 4 performance categories to 0% (rather
than just the categories included in your MIPS EUC Exception application). We'll score any performance category for which
qualifying data is submitted.

Example
Scenario

Outcome
You'll receive a MIPS final score based on the qualifying
data submitted.

You're planning to report traditional MIPS or registered to
report an MVP. You submit an application to have all 4
performance categories reweighted to 0% but later
determine you're able to report the improvement
activities and Promoting Interoperability performance
categories.

• The improvement activities performance category will
be weighted at 15%.
• The Promoting Interoperability performance category
will be weighted at 85%.
• The quality performance category will retain a 0%
weight because you didn't submit quality data.
• The cost performance category will retain a 0% weight
because there are no data submission requirements
associated with the cost performance category
(reweighting can't be voided).

9

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Individual Clinicians and Groups Reporting the APP
Example
Scenario

Outcome
You'll receive a MIPS final score based on the data
submitted.

• The improvement activities performance category will
You're a MIPS eligible clinician (or group) planning to
be weighted to 25%.
report the APP. You submit an application to reweight the • The Promoting Interoperability performance category
quality performance category and your application was
will be weighted to 75%.
approved.
• The quality performance category will be weighted at
0% provided no qualifying data is submitted.
• The cost performance category will retain a 0% weight
(because cost isn't scored under the APP).

10

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Policies for Subgroups Reporting an MVP
Clinicians who register to report an MVP as a subgroup will inherit the performance category reweighting
approved for their affiliated group. That is, subgroups will inherit any reweighting approved for their affiliated
group. However, a qualifying data submission can affect performance category reweighting:
• A qualifying data submission by the affiliated group won't override performance category reweighting for
the subgroup.
• A qualifying data submission by the subgroup won't override performance category reweighting for the
affiliated group, it will only override performance category reweighting for the subgroup.
• Subgroups can't submit a MIPS EUC Exception application as outlined in this guide.

Note: Subgroups can't request reweighting independent of their affiliated
group's status.

11

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION OVERVIEW

Policies for APM Entities (Continued)
•

APM Entity applications must be submitted for all performance categories.
◦ You can't submit an application to request reweighting in 1 or 2 performance categories.
◦ This is different from our policy for individual, group, and virtual group applications.

•

If your APM Entity's application is approved, the APM Entity will receive a final score equal to the performance threshold even if
qualifying data is submitted for the APM Entity.
◦ The MIPS eligible clinicians in the APM Entity will receive a neutral MIPS payment adjustment unless they have a higher
final score from individual or group participation.
◦ A qualifying data submission for an APM Entity will not override performance category reweighting from an approved
application.
◦ This is different from our policy for individual, group, and virtual group applications.

•

At least 75% of MIPS eligible clinicians in an APM Entity must qualify for reweighting of the Promoting Interoperability
performance category.
◦ Given that APM Entities are required to request reweighting for all performance categories in their EUC Exception
application, at least 75% of the MIPS eligible clinicians in the Entity will need to qualify for reweighting in the Promoting
Interoperability performance category.
◦ They may qualify automatically or by meeting one of the reasons identified in the MIPS Promoting Interoperability
Hardship Exception Application.

•

APM Entity representatives must have a QPP Security Official role to complete the Extreme and Uncontrollable Circumstances
Exception application on behalf of their entity.
◦

•

Review the Connect to an Organization resource in the QPP Access User Guide (ZIP, 4MB) for more information on
obtaining the Security Official role. For a list of active APMs please refer the 2024 and 2025 Comprehensive List of APMs.

An approved application won't affect your model-specific reporting requirements.
◦ For example, Shared Savings Program ACOs must report the quality measures identified in the APP to meet Shared Savings
Program requirements, unless otherwise excepted.
12

MIPS Extreme and
Uncontrollable
Circumstances Exception
Application Process:
Frequently Asked
Questions

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: FREQUENTLY ASKED QUESTIONS

How Does CMS Assess MIPS EUC Exception Applications?
We consider the variables affecting your ability to collect
and submit data for each performance category when
reviewing your application for performance category
reweighting due to extreme and uncontrollable
circumstances.
During our review, we will review both the event
circumstances and the length of time you were impacted
as indicated in your application to assess your ability to
submit data for each performance category selected in
the application.

Example:
The performance period for an improvement activity
is a continuous 90-day period (or as specified in the
activity description) whereas the performance
period for the quality performance category is 12
months. An issue lasting 3 months may have more
impact on the availability of measures for the quality
performance category than your ability to perform
and attest to improvement activities.

How Long Does it Take to Process an EUC Exception Application?
The length of time it takes to process applications depends on the volume of applications we receive. We
review all applications in the order that they were received. Once a decision is made regarding your
application, you'll receive a notice of our decision, and the status of your application will be reflected in your
QPP Account on the QPP website.

Where Can I Look for a Status Update on My EUC Exception
Application?
You can monitor your application status in your QPP Account on the QPP website.

14

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: FREQUENTLY ASKED QUESTIONS

Are We Required to Submit Documentation with Our EUC
Exception Application?
• No, you aren't required to submit documentation with your application.
• However, you should retain documentation of the circumstances supporting your application for your own
records in the event that you are selected by CMS for data validation or an audit. See our 2025 MIPS Data
Validation Criteria Guide (ZIP, 2MB) for information on the data validation and audit process.

How Can I Correct a Mistake Made on Our EUC Exception
Application?
• If you identified an error with your application, please contact the Quality Payment Program Service Center
by email at [email protected], by creating a QPP Service Center ticket, or by phone at 1-866-288-8292
(Monday-Friday, 8 a.m. - 8 p.m. ET).

Can Additional Staff Members Access/Receive Notifications About
the Status of Our EUC Exception Application?
• Yes, you can add additional staff or representatives who should receive notifications about the status of the
application.
• In the Additional Access section of the application, provide the email address(es) of additional staff or
representatives who you would like to receive email notifications.
• Please note that the additional staff or representatives must have HARP credentials to see the application on the
QPP website.
Important Note: Corrections can't be made after the application period has closed.

15

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: FREQUENTLY ASKED QUESTIONS

Can We Submit one MIPS EUC Exception Application at the Group
Level rather than Separate Applications for Each Individually Eligible
Clinician?
• Yes, you can submit a group-level application instead of separate applications for each clinician if the EUC
applies to the whole group. However, if the circumstances are specific to a subset of clinicians in the group,
you'd need to submit individual applications for each of those clinicians.

Our Third Party Intermediary Experienced Issues and Is Unable to
Submit Data on Our Behalf. Can We Submit an EUC Exception
Application for this Issue?
• Our EUC policy doesn't include third party intermediaries, such as Electronic Health Record vendors (EHRs),
QCDRs, or Qualified Registries that submit data on behalf of a MIPS eligible clinician. Instead, this policy is geared
towards events, such as natural disasters or ransomware attacks, that affect the MIPS eligible clinician's ability to
collect and submit data to the third party intermediary, which in turn, could affect the ability of the clinician (or
the third party intermediary acting on their behalf) to successfully submit measures and activities to MIPS.
• Furthermore, the MIPS EUC Exception Application is available during the performance year; if you discover during
the performance year that your third party intermediary is having issues, you may need to find another third
party intermediary to submit your data. You can also submit your own data by uploading a file or attesting to
certain performance categories.
• If you discover during or after the submission period that your third party intermediary is unable to (or didn't)
submit your data, please contact the Service Center.
16

MIPS Extreme and
Uncontrollable
Circumstances Exception
Application Process:
Application Steps

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 1: Sign in to Your QPP Account
With your HARP credentials, sign in to your
QPP Account on the QPP website.

Note: If you haven't signed in on the QPP
website before, you must register for an
account to obtain your HARP credentials.

*The screenshots included in this user guide were based on the QPP
test environment. Because we are always working to incorporate
feedback and improve the experience, there may be differences
between these screenshots and what you see on the QPP website.

18

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 2: Navigate to Your Exception Applications
Once you're signed into your account,
select:​
• The Exception Application tab in
the left-hand navigation menu,
then click + Add New QPP
Exception
OR
•

The Start an Application quick link
on the home page.

*The screenshots included in this user guide were based on the QPP
test environment. Because we are always working to incorporate
feedback and improve the experience, there may be differences
between these screenshots and what you see on the QPP website.

19

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 3: Select Extreme and Uncontrollable Circumstances
Exception
Select the Extreme and Uncontrollable Circumstances Exception, then click Continue.

*The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate
feedback and improve the experience, there may be differences between these screenshots and what you see on the QPP website.

20

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 4: Select Application Type
Select the participation level at which you
intend (or intended) to participate in MIPS,
then select Save & Continue.

Note: If reporting an MVP with a subgroup,
you will inherit any reweighting approved for
your affiliated group.
Subgroups can't request reweighting
independent of their affiliated group's status.

*The screenshots included in this user guide were based on the QPP
test environment. Because we are always working to incorporate
feedback and improve the experience, there may be differences
between these screenshots and what you see on the QPP website.

21

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 5: Enter Participation Level Information
Enter the required participation level information.
The required information for each participation level is as follows:
Participation
Level
Individual
Clinician
Group
Virtual Group
APM Entity

Required Information
• National Provider Identifier (NPI)
• Practice Affiliation
• Taxpayer Identification Number
(TIN)
• Virtual Group Identifier
• APM Entity ID

Note: If you're an individual clinician, group, or virtual
group requesting reweighting of only 1 or 2 MIPS
performance categories and intend to submit data for
others, it is critical that you select the application type
that aligns with the level at which you intend to submit
data to MIPS (i.e., at the individual, group or virtual
group level).

*The screenshots included in this user guide were based on the QPP
test environment. Because we are always working to incorporate
feedback and improve the experience, there may be differences
between these screenshots and what you see on the QPP website.

22

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 6: Enter Submitter Details
Enter your contact information (as the submitter)
and identify your relationship to the party identified
in the application.

*The screenshots included in this user guide were based on the
QPP test environment. Because we are always working to
incorporate feedback and improve the experience, there may
be differences between these screenshots and what you see on
the QPP website.

23

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 7: Enter Additional Staff in the Additional Access Section
You can identify additional users to receive notifications about the application in the Additional Access section.
If there's a HARP account associated with the email address(es) you provide, the person will be able to sign in
to their QPP Account on the QPP website and access the application.

*The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate
feedback and improve the experience, there may be differences between these screenshots and what you see on the QPP website.

24

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 8: Enter the Extreme and Uncontrollable Circumstances
Event Type
Select the appropriate Event Type for the
extreme and uncontrollable circumstance
you experienced.
Then, enter the timeframe for which you
were impacted by the extreme and
uncontrollable event by completing the
Event Date Range. If you continue to be
impacted by the event, select Event Still
Persists.
Note: The 2019 COVID-19 PHE ended on May
11, 2023. We're not accepting applications due
to COVID-19 for the 2025 performance year.
*The screenshots included in this user guide were
based on the QPP test environment. Because we are
always working to incorporate feedback and improve
the experience, there may be differences between
these screenshots and what you see on the QPP
website.

25

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 9: Provide a Brief Description of the Challenges You
Experienced
Provide a brief description about the data collection challenges that you experienced due to the extreme and
uncontrollable event and how your 2025 performance data will be impacted.

Note: You don't need to submit supporting documentation with your application.
However, you should retain documentation of the circumstances supporting your application for your own records in the event
that you're selected by CMS for data validation or an audit.
See our 2025 MIPS Data Validation Criteria (ZIP, 2MB) for information on the data validation and audit process.
*The screenshots included in this user guide were based on the QPP test environment. Because we are always working to incorporate
feedback and improve the experience, there may be differences between these screenshots and what you see on the QPP website.
26

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 10: Select MIPS Performance Categories
Select each MIPS performance category for which you're
requesting reweighting by checking the corresponding box
next to the category name, then select Submit for Review.

Note: All performance categories will be automatically
selected for APM Entity applications.

*The screenshots included in this user guide were based on the QPP test
environment. Because we are always working to incorporate feedback and
improve the experience, there may be differences between these screenshots
and what you see on the QPP website.

27

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 11: Submit Extreme and Uncontrollable Circumstances
Application
Once you're done with your application,
review the disclosures, then select the
Certify & Submit button.

*The screenshots included in this user guide were
based on the QPP test environment. Because we are
always working to incorporate feedback and improve
the experience, there may be differences between
these screenshots and what you see on the QPP
website.

28

MIPS EXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
APPLICATION PROCESS: APPLICATION STEPS

Step 11: Submit Extreme and Uncontrollable Circumstances
Application – continue
After you submit your application, you'll receive a message stating that your application has been
successfully submitted and is pending review. You'll also receive an email notification.

*The screenshots included in this user guide were based on the QPP test environment. Because we are always working to
incorporate feedback and improve the experience, there may be differences between these screenshots and what you see on
the QPP website.

29

Help and Version
History

HELP AND VERSION HISTORY

Where Can You Go for Help?

Contact the Quality Payment Program Service Center
by email at [email protected], by creating a QPP
Service Center ticket, or by phone at 1-866-288-8292
(Monday through Friday, 8 a.m. - 8 p.m. ET). To
receive assistance more quickly, please consider
calling during non-peak hours—before 10 a.m. and
after 2 p.m. ET.
People who are deaf or hard of hearing can dial 711 to
be connected to a TRS Communications Assistant.

Visit the Quality Payment Program
website for other help and support
information, to learn more about
MIPS, and to check out the resources
available in the Quality Payment
Program Resource Library.

Visit the Small Practices page of
the Quality Payment Program
website where you can sign up
for the monthly QPP Small
Practices Newsletter and find resources
and information relevant
for small practices.

31

HELP AND VERSION HISTORY

Version History
If we need to update this document, changes will be identified here.
D AT E
05/06/2025

DESCRIPTION
Original Posting.

According to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.), no persons are required to respond to a collection of
information unless it displays a valid OMB control number. The valid OMB control number for this information collection is 0938-1314
(Expiration date: 2/28/2027). This information collection is the tool for the MIPS Extreme and Uncontrollable Circumstances (EUC) Exception
application allows you to request reweighting for one or more performance categories to 0%. The time required to complete this
information collection is estimated to average varies per response, including the time to review instructions, search existing data resources,
gather the data needed, to review and complete the information collection. This information collection is voluntary and All information
collected will be kept private in accordance with regulations at 45 CFR 155.260, Privacy and Security of Personally Identifiable Information.
Pursuant to this regulation, CMS may only use or disclose personally identifiable information to the extent that such information is
necessary to carry out their statutory and regulatory mandated functions. If you have comments concerning the accuracy of the time
estimate(s) or suggestions for improving this form, please write to: CMS, 7500 Security Boulevard, Attn: PRA Reports Clearance Officer, Mail
Stop C4-26-05, Baltimore, MD 21244-1850. If you have questions or concerns regarding where to submit your documents, please contact
QPP at [email protected].
Under the Privacy Act of 1974 (5 U.S.C. 552a) any personally identifying information obtained will be kept private to the extent of the law.

32

Appendices

APPENDICES

Appendix A1. 2025 Performance Year MIPS Performance Category
Weight Redistribution Policies for Individual Clinicians, Groups,
Virtual Groups, and APM Entities Reporting Traditional MIPS or MVPs
The table below illustrates the 2025 performance category
weights and reweighting policies that CMS will apply to
clinicians, groups, and virtual groups reporting traditional MIPS
or MVPs. (Small practices should refer to Appendix A2.)

Refer to Appendix B for reweighting policies for APM Entities
reporting the APP. APM Entities reporting traditional MIPS
can only request reweighting for all performance categories.

If fewer than 2 performance categories can be scored (meaning 1 performance category is weighted at 100%, or all performance
categories are weighted at 0%), the clinician, group, or virtual group will receive a final score equal to the performance threshold
and the MIPS eligible clinicians will receive a neutral payment adjustment in the 2027 payment year.
Quality Category
Weight

Cost Category
Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

30%

30%

15%

25%

No Cost
(Cost → Quality and Promoting Interoperability)

55%

0%

15%

30%

No Improvement Activities
(Improvement Activities → Quality)

45%

30%

0%

25%

No Promoting Interoperability
(Promoting Interoperability → Quality)

55%

30%

15%

0%

No Quality
(Quality → Promoting Interoperability)

0%

30%

15%

55%

MIPS Performance Category Reweighting
Scenario
No Reweighting
Standard Weighting under traditional MIPS
Reweight 1 Performance Category

Table continues on the following slide.

34

APPENDICES

Appendix A1. 2025 Performance Year MIPS Performance Category Weight
Redistribution Policies for Individual Clinicians, Groups, Virtual Groups,
and APM Entities Reporting Traditional MIPS or MVPs (Continued)
MIPS Performance Category Reweighting Scenario

Quality Category
Weight

Cost Category
Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

85%

0%

15%

0%

0%

0%

15%

85%

70%

0%

0%

30%

0%

50%

50%

0%

70%

30%

0%

0%

0%

30%

0%

70%

Reweight 2 Performance Categories
No Cost + No Promoting Interoperability
(Cost + Promoting Interoperability → Quality)
No Cost + No Quality
(Cost + Quality → Promoting Interoperability)
No Cost + No Improvement Activities
(Cost + Improvement Activities → Promoting
Interoperability + Quality)
No Promoting Interoperability + No Quality
(Promoting Interoperability + Quality → Cost +
Improvement Activities)
No Promoting Interoperability + No Improvement
Activities
(Promoting Interoperability + Improvement
Activities → Quality)
No Quality + No Improvement Activities
(Quality + Improvement Activities → Promoting
Interoperability)
Reweight 3 Performance Categories
If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you'll receive a
score equal to the performance threshold and you'll receive a neutral payment adjustment.
Reweight 4 Performance Categories
If all performance categories are reweighted to 0%, you'll receive a score equal to the performance threshold and you'll receive a neutral payment adjustment.

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APPENDICES

Appendix A2. MIPS Performance Category Weight Redistribution
Policies Under Traditional MIPS Finalized for the 2025
Performance Year: Small Practices
The table below illustrates the 2025 performance
category weights and reweighting policies that CMS
will apply to small practices.

Refer to Appendix B for reweighting policies that apply to APM
Entities reporting the APP. APM Entities reporting traditional MIPS or
MVPs can only request reweighting for all performance categories.

Quality Category
Weight

Cost Category
Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

30%

30%

15%

25%

No Cost
(Cost → Quality and Promoting Interoperability)

55%

0%

15%

30%

No Improvement Activities
(Improvement Activities → Quality)

45%

30%

0%

25%

No Promoting Interoperability
(Promoting Interoperability → Quality and
Improvement Activities)

40%

30%

30%

0%

No Quality
(Quality → Promoting Interoperability)

0%

30%

15%

55%

MIPS Performance Category Reweighting
Scenario
No Reweighting
Standard Weighting under traditional MIPS for
small practices
Reweight 1 Performance Category

Table continues on the following slide.

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APPENDICES

Appendix A2. MIPS Performance Category Weight
Redistribution Policies Under Traditional MIPS Finalized for the
2025 Performance Year: Small Practices
MIPS Performance Category Reweighting
Scenario
Reweight 2 Performance Categories
No Cost + No Promoting Interoperability
(Cost + Promoting Interoperability → Quality
and Improvement Activities)
No Cost + No Quality
(Cost + Quality → Promoting Interoperability)
No Cost + No Improvement Activities
(Cost + Improvement Activities → Promoting
Interoperability + Quality)
No Promoting Interoperability + No Quality
(Promoting Interoperability + Quality → Cost +
Improvement Activities)
No Promoting Interoperability + No Improvement
Activities
(Promoting Interoperability + Improvement
Activities → Quality)
No Quality + No Improvement Activities
(Quality + Improvement Activities → Promoting
Interoperability)

Quality Category
Weight

Cost Category
Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

50%

0%

50%

0%

0%

0%

15%

85%

70%

0%

0%

30%

0%

50%

50%

0%

70%

30%

0%

0%

0%

30%

0%

70%

Note: If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of
your final score, you'll receive a score equal to the performance threshold and you'll receive a neutral payment adjustment.

37

APPENDICES

Appendix B. 2025 Performance Year MIPS Performance
Category Weight Redistribution Policies for APM Entities and APM
Participants Reporting the APP
The table below illustrates the 2025 performance category weights and reweighting policies that
CMS will apply to APM Entities reporting traditional MIPS or MVPs and to individual clinicians,
groups and APM Entities reporting via the APP.

Reminder: APM Entities
can only submit an EUC
Exception Application for
all performance
categories.

Reminders:
• Cost isn't scored under the APP.
• There are no reporting requirements for the improvement activities performance category under the APP for the 2025
performance year. Participants reporting via the APP will automatically receive full credit for the improvement activities
performance category.
• Participants reporting via the APP will follow the same reporting requirements as traditional MIPS for the Promoting
Interoperability performance category.
MIPS Performance Category Reweighting
Scenario

Quality Category
Weight

Cost Category
Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

50%

0%

20%

30%

75%

0%

25%

0%

0%

0%

25%

75%

No Reweighting
Standard Weighting under the APP
Reweight 1 Performance Category
No Promoting Interoperability
(Promoting Interoperability → Quality)
No Quality
(Quality → Promoting Interoperability)
Reweight 2+ Performance Categories
If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you'll
receive a score equal to the performance threshold and you'll receive a neutral payment adjustment.

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APPENDICES

Appendix C. MIPS Extreme and Uncontrollable Circumstances
Exception Application Status Descriptions
Draft in Progress

Submitted – Pending Approval

Approved / Denied

We completed our review of your
application and approved your
request.
You're currently working on your
application and haven't
submitted it yet.

Select Manage to continue
working on your application.

You've successfully completed
and submitted your application.
Applications are reviewed in the
order of which they're received.
We completed our review of your
application and denied your
request.

Withdrawn

You've withdrawn your
application. You can withdraw
your application at any point in
the process.
An application can't be reopened
after being withdrawn. You'll
need to complete a new
application.

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APPENDICES

Appendix D. Minimum Criteria for a Qualifying Data Submission
The minimum criteria for a qualifying data submission (i.e., eligible for scoring) in the quality, improvement activities, and Promoting
Interoperability performance categories are:
• Quality Performance Category: A qualifying data submission for the quality performance category must include numerator and
denominator information for at least one quality measure from the list of MIPS quality measures to be considered a data
submission and scored. Data submissions without any scorable data (e.g., practice ID, date, activity ID, measure ID, or CMS
Electronic Health Record (EHR) Certification ID (CEHRT ID)) wouldn't satisfy the submission criteria.
• Improvement Activities Performance Category: A qualifying data submission for the improvement activities performance category
must include a “yes” response for at least one improvement activity to be considered a data submission and scored. A submission
with only a date and practice ID won't be considered a data submission and will be assigned a null score.
• Promoting Interoperability Performance Category: A qualifying data submission for the Promoting Interoperability performance
category must include all of the following elements:
◦ Performance data, including any claim of an applicable exclusion, for the required measures in each objective, as specified
by CMS;
◦ Required attestation statements, as specified by CMS;
◦ CMS EHR Certification ID (CEHRT ID) from the Certified Health IT Product List (CHPL); and
◦ The start date and end date for the applicable performance period as set forth in § 414.1320.
A Promoting Interoperability data submission with only a date and practice ID won't be considered a qualifying data submission and
will be assigned a null score; it won't override reweighting of the Promoting Interoperability performance category.
The minimum criteria for a qualifying data submissions is intended to mitigate the negative scoring impact on clinicians due to
unintentional submissions without data that can be scored, which would override an approved reweighting application or a prior
data submission and result in a zero score.

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