The Centers for Medicare and Medicaid Services (CMS) recently announced that they have identified certain counties in California and Texas as qualifying for an automatic 2025 MIPS extreme and uncontrollable circumstances (EUC) hardship. Meaning that MIPS eligible individual clinicians will be eligible for an automatic hardship for the 2025 performance year as long as they do not submit any MIPS data.
This announcement comes in recognition of the devastating impact of the Los Angeles wildfires and, most recently, the Texas flooding.
Is my location eligible for an automatic hardship?
The affected counties in these territories are reflected in green in the maps shown below and have been included in CMS’ list of the areas qualifying for a 2025 MIPS automatic EUC. Click on each state to see the list and the map of counties eligible for the automatic hardship.
CMS added counties to the list of areas eligible for an automatic EUC on July 30, 2025. Certain counties in Texas are now included. Below is a table of the most recent additions:
- Edwards
- Lampasas
- Real
- Reeves
- Schleicher
- Sutton
- Uvalde
- Los Angeles
- Burnet
- Coke
- Concho
- Edwards
- Hamilton
- Kendall
- Kerr
- Kimble
- Lampasas
- Llano
- Mason
- McCulloch
- Menard
- Real
- Reeves
- San Saba
- Schleicher
- Sutton
- Tom Green
- Travis
- Uvalde
- Williamson
Important Notes for Those in the Identified Areas
- Clinicians might be automatically scored on certain categories in the following circumstances:
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 the announcement of the automatic EUC, will be scored at the individual level on Quality (1 MIPS category).
- If you are part of an APM Entity: You will receive a MIPS Final Score and payment adjustment associated with the higher of your individual or APM Entity scores.
- Group reporting is optional. If you have not reported and do not report any 2025 MIPS data at the group level, your clinicians will only be evaluated at the individual level (and have the automatic EUC applied).
You can still report on the individual level, if you would like.
- If you group report and you do not exceed the low-volume threshold at the individual level, you will only receive the group score.
- If you submit data on 2+ MIPS categories, CMS will score you on the reported categories and assign you a 2025 MIPS final score and 2027 payment adjustment.
Reminder: Clinicians in APMs are automatically scored on Improvement Activities and clinicians who have submitted quality data codes on Medicare Part B claims at any point in 2025 will receive a Quality category score. If a clinician is both in an APM and has submitted any 2025 quality data codes on Medicare Part B claims, they will automatically have 2 MIPS categories scored.
Next Steps
- Share this information with your colleagues.
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- If you are an Anatomy IT client
Contact your Client Success Manager if you have any questions or if you plan on using this automatic hardship. Your Client Success Manager will help you evaluate your eligibility and retain the necessary documentation on your behalf.
- Contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.
If you have any questions on this, let us know!
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Written By: **Jessica Peterson, MD, MPH
About the Author: Jessica Peterson, MD, MPH is the Senior Director of Value-Based Care Policy at Anatomy IT.