Online Publication Date:
27 Mar 2025
CMS Grants ASN's and AMA's Request to Reopen Applications for MIPS Extension of EUC Hardship Exception

The hardship exception will apply to the 2024 performance period, which will adjust Medicare payments in 2026.
By:
David White
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The Centers for Medicare and Medicaid Services (CMS) recently granted a request from ASN and the American Medical Association (AMA) to reopen applications for the Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances (EUC) hardship exception for performance year 2024 due to the intravenous (IV) fluid shortage caused by  Hurricane Helene last fall.  

The decision follows steadfast advocacy, involving collaboration between ASN, the White House, and Baxter International to restore the US supply of sterile peritoneal dialysis fluid and IV solutions following the hurricane's damage to Baxter’s Marion, NC plant.

Physicians will be able to submit an EUC hardship exception application between March 31 and April 14, 2025 to avoid a MIPS penalty of up to -9% if they were affected by the shortage. This hardship exception will apply to the 2024 performance period, which will adjust Medicare payments in 2026. 

To avoid a MIPS penalty, physicians who were affected by the IV fluid shortage should submit an EUC application requesting reweighting of all four MIPS categories: quality, cost, promoting interoperability, and improvement activities. CMS will not reweight any performance category for which the agency has received data. However, if three performance categories are reweighted to 0% and only one performance category can be scored, then the physician or group will earn a final score equal to the performance threshold and avoid a MIPS penalty. 

Additionally, because the MIPS cost performance category relies entirely on claims-based measures that do not require submission from physicians or groups, ASN recommends requesting reweighting of this category if a physician or group needed to conserve IV fluids, use alternatives, restrict access to elective surgery or take any other measures due to the nationwide IV fluid shortage. 

CMS is extending the MIPS data submission window for the 2024 performance period for two weeks: from March 31 to April 14, 2025 (until 8 p.m. EDT). 

For more information, visit https://qpp.cms.gov/ . 
 

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