The Medicare Shared Savings Program generally requires participating providers to report objectives and measures for the Merit-based Incentive Payment System (“MIPS”) in several performance categories, including “Promoting Interoperability” through the use of electronic health records (“EHR”). However, CMS recognizes that some situations beyond providers’ control may impede their ability to comply with the reporting requirements, so providers may apply for and receive exemptions (referred to as “exceptions”) to MIPS reporting requirements in situations categorized as “Extreme and Uncontrollable Circumstances” (“EUC”) (which apply to all MIPS performance categories) or “Hardships” (which apply to the Promoting Interoperability performance category). Some examples of EUC situations include natural disasters such as floods or wildfires, and cyberattacks. Examples of hardships include loss of internet connectivity, and unavailability of certified EHR technology. This year, CMS has expanded the categories in which it will consider exceptions.
Eligible clinicians can submit exception applications until December 31, 2025 at 8:00 pm, to avoid payment penalties for failure to fulfill the MIPS reporting requirements.
CMS’s FAQs on MIPS Promoting Interoperability reporting are available here: MIPS Promoting Interoperability (PI) Performance Category Certified Electronic Health Record Technology.