2024 MIPS Hardship Application Deadline Approaching

The deadline to file for a 2024 MIPS hardship is rapidly approaching. The Centers for Medicare and Medicaid Services (CMS) requires 2024 MIPS hardship applications to be submitted by December 31, 2024 at 8 pm ET.

There are two applications available, the Extreme and Uncontrollable Circumstance (EUC) hardship application and the Promoting Interoperability (PI) exception application. Both applications are available in your QPP account.

If you were affected by a tropical storm or hurricane this year, you may be eligible for an automatic hardship. Take a look at the eligible counties and read important notes about the automatic hardship in our previous blog.

Factors CMS Considers in Hardship Applications

CMS reviews applications taking into account both the event circumstances (what happened) and the timing (how long the circumstances impacted you) to assess your ability to collect and/or submit data for each performance category selected in the application.

For the Cost and Quality category exceptions, CMS generally expects the circumstance to have lasted for at least 3 months.

For example, a natural disaster or ransomware attack that prevented you from collecting Quality data for 3 or more months.

For example, if you switch EHR vendors during the performance period, you may claim a PI hardship for vendor issues.

Reweighting Scenarios

Steps to Apply

If you are an Anatomy IT client, contact your MIPS Expert to complete this process for you, otherwise:

Sign in to your QPP account.
Select “Exception Applications” on the left-hand navigation.
Select “Add New QPP Exception.”
Select either “MIPS Promoting Interoperability Performance Category Hardship Exception” or “Extreme and Uncontrollable Circumstances Exception.”
Complete the application at either the individual, group, virtual group, or APM Entity participation level.

Note: you must complete the hardship application at the level for which you will report data to MIPS. Group applications will not apply to individual reporters and vice versa.

Follow these links for more information on PI Hardship Applications (PDF) and EUC Hardship Applications (PDF).

Important Notes

The deadline to submit hardship applications is December 31, 2024 at 8 pm ET.

Retain documentation of the hardship for at least six years in case of an audit.

Hardships from previous years do not carry forward. You must submit a new application each year in which you experience a hardship.
CMS is not accepting applications due to COVID-19 for the 2024 performance year.
Clinicians in APMs automatically receive Improvement Activities credit and so are automatically scored on at least 1 MIPS category.
Submitting Quality Data Codes on Medicare Part B Claims: clinicians/groups submitting quality data codes on claims, even if only submitted prior to applying for a hardship, will be scored at the individual level on Quality (1 MIPS category).
Do not submit data in the categories for which you received a hardship exception or CMS will score those categories.
If you submit data on 2+ MIPS categories, CMS will score you on the reported categories and assign you a 2024 MIPS final score and 2026 payment adjustment.
If you submit data on 1 or fewer MIPS categories (such as small practice claims-based Quality reporters), CMS will assign you a 2024 MIPS score equal to the threshold to avoid a penalty.
If you get a hardship for all categories, CMS will assign you a score equal to the threshold to avoid a penalty.

Next Steps

Share this information with your colleagues.
Subscribe to our blog to get alerts on this and other important issues. You can subscribe using the field in our website footer below.
If you are an Anatomy IT client:

Contact your MIPS Expert if you have any questions or if you plan on applying for a hardship. Your MIPS Expert will help you evaluate your eligibility and retain the necessary documentation on your behalf.

If you have any questions on this, let us know!

Written By: **Sarrah Hakim, MHSA

About the Author: Sarrah is a Manager of Health Policy at Anatomy IT.