Learn about the EUC exception, automatic reweighting, facility-based scoring, PI measure suppression policy, advanced APM and much more, through the Frequently Asked Questions (FAQs) below. Please schedule a consultation if you are looking for a Security Risk Analysis (SRA) for MIPS or Expert Consultants to help you navigate the process.
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What is the MIPS Extreme and Uncontrollable Circumstances (EUC) exception?
The Extreme and Uncontrollable Circumstances (EUC) exception allows clinicians, groups, and virtual groups to apply for reweighting of any or all MIPS performance categories when rare events entirely outside their control, such as a natural disaster, a public health emergency, or a significant practice disruption, make normal reporting impossible or impractical. Approved EUC exceptions may reweight affected categories to 0%, effectively removing them from the composite score calculation. Clinicians in CMS-designated disaster areas may qualify for automatic EUC application, with all four categories reweighted to 0% unless the clinician voluntarily submits data for two or more categories. Beginning with the 2025 performance year and continuing in 2026, CMS expanded the EUC policy to cover clinicians and ACOs impacted by cyberattacks such as ransomware or malware, recognizing the growing operational threat of cyber incidents to healthcare practices.
What is the Promoting Interoperability Hardship Exception?
The Promoting Interoperability (PI) Hardship Exception allows clinicians to request that the PI category be reweighted to 0%, with its weight redistributed to other categories, when circumstances prevent them from meeting PI requirements for reasons unrelated to an EUC event. Qualifying grounds include insufficient internet connectivity, certified EHR technology vendor problems, or extreme financial distress that makes CEHRT participation cost prohibitive. When approved for non-small practices, the full 25% PI weight shifts entirely to Quality, bringing it to 55% of the total score. Small practices are not required to apply for the PI Hardship Exception, they receive automatic PI reweighting to 0% as a standing accommodation, with the freed weight split between Quality (40%) and Improvement Activities (30%).
What accommodations are available for small practices?
For the 2026 performance year, small practices, defined as those with 15 or fewer clinicians under a single TIN, receive four automatic accommodations without any application required: reweighting of the Promoting Interoperability category to 0%, with the freed weight redistributed to Quality (40%) and Improvement Activities (30%); a 6-point bonus added to the final composite score; the 3-point scoring floor for quality measures that meet data completeness and case minimums; and, for multispecialty small practices, the option to register and report as a single group under an MVP rather than forming subgroups, an exemption CMS finalized specifically for this practice size in the 2026 rule.
What is automatic reweighting, and which clinicians qualify for it?
Automatic reweighting occurs when CMS removes one or more performance categories from a clinician’s score calculation and redistributes the corresponding weight to the remaining categories, without the clinician needing to file any application. For the PI category, four groups qualify automatically: hospital-based clinicians (where more than 75% of the group’s eligible clinicians bill primarily in the hospital setting), non-patient-facing clinicians or groups (where more than 75% of the group qualifies as non-patient-facing), ASC-based clinicians, and small practices (15 or fewer clinicians in the TIN). For hospital-based, non-patient-facing, and ASC-based clinicians, the full PI weight (25%) flows to Quality only, bringing Quality to 55% of the total score. For small practices, the PI weight is split between Quality (now 40%) and Improvement Activities (now 30%). Clinicians who qualify for automatic reweighting but choose to report PI data anyway can override the reweighting, in that case, their reported PI data is scored at the full 25% weight, and Quality reverts to its standard 30%.
What is facility-based scoring, and who qualifies for it?
Facility-based scoring allows clinicians who furnish at least 75% of their covered professional services in a hospital setting to have their Quality and Cost category scores replaced by the Total Performance Score of their attributed hospital under the Hospital Value-Based Purchasing (VBP) Program, but only when doing so produces a higher final MIPS composite score than the clinician’s own reported data would yield.
To qualify, a clinician must furnish 75% or more of their covered professional services using Place of Service codes 21 (inpatient hospital), 22 (on-campus outpatient hospital), or 23 (emergency room); bill at least one service in an inpatient hospital or emergency room; and be attributed to a facility that participates in the Hospital VBP Program with a Total Performance Score for the applicable fiscal year. A group qualifies as facility-based when 75% or more of the MIPS-eligible clinicians billing under the TIN individually meet this definition. Clinicians who work at multiple facilities are attributed to the one where they provided services to the greatest number of Medicare beneficiaries.
No separate opt-in is required, the higher of the two scores is applied automatically. Facility-based clinicians can verify their status and preview their attributed facility’s projected score using the Facility Based Preview tool at qpp.cms.gov. Some hospitals, including those in Maryland and those without a VBP score due to insufficient quality data, do not have a Hospital VBP Total Performance Score, in which case facility-based scoring is not available and the clinician must report MIPS Quality measures through another method. Note that facility-based scoring is a separate and distinct policy from hospital-based status: hospital-based status governs automatic PI reweighting, while facility-based measurement governs Quality and Cost category replacement.
What is the PI measure suppression policy, and how does it work?
Beginning with the 2026 performance year, CMS adopted a formal measure suppression policy for the Promoting Interoperability category, under which CMS may suppress specific PI measures when circumstances outside a clinician’s control, such as technical failures, partner system outages, or programmatic pauses by external agencies, affect a particular measure. A suppressed measure is not scored, but the clinician receives the maximum available points for it automatically. Critically, the affected measure must still be reported; suppression affects only the scoring, not the reporting obligation, failing to report a suppressed measure results in zero points for the objective it falls under. The eCR (Electronic Case Reporting) measure is the current active example: the CDC’s ongoing pause on onboarding new healthcare organizations to the electronic case reporting network means the eCR measure remains suppressed for 2026 and beyond. Clinicians must still report a “Yes,” “No,” or “Excluded” response for the eCR measure, failing to report at all results in zero points for the Public Health and Clinical Data Exchange objective, but the response given has no effect on scoring and full credit is awarded regardless.
What is an Advanced Alternative Payment Model (Advanced APM), and what is Qualifying APM Participant (QP) status?
An Advanced Alternative Payment Model (Advanced APM) is a Medicare payment model that satisfies three criteria established by MACRA: it requires participants to use certified EHR technology, it bases payments on quality measures comparable to those in MIPS, and it requires participants to bear more than nominal financial risk for performance outcomes. Examples include the Medicare Shared Savings Program Track E and certain Innovation Center models meeting the financial risk threshold. Qualifying APM Participant (QP) status is achieved when a clinician’s Medicare patient or payment volume attributable to an Advanced APM exceeds the applicable QP threshold during the determination period. Clinicians with QP status are excluded from MIPS payment adjustments entirely, they neither receive MIPS bonuses nor face MIPS penalties. The 5% lump-sum Advanced APM incentive payment available under MACRA for payment years 2019 through 2024 expired after the 2024 payment year and does not apply to the 2026 performance year or its resulting 2028 payment adjustments. Even without that incentive, QP status remains advantageous because it fully exempts clinicians from the MIPS penalty structure.
What changed for Advanced APM participants in 2026?
For 2026, CMS introduced individual-level Qualifying APM Participant (QP) status determinations for Advanced APM participants, in addition to the existing APM Entity-level determinations. Previously, a clinician could only achieve QP status, and thereby step outside MIPS payment adjustments, if their entire APM Entity met the qualifying threshold. Under the new policy, individual clinicians can achieve QP status based on their own participation volume, even if the broader APM Entity as a whole does not meet the threshold. CMS also expanded the range of services used in QP threshold calculations beyond the previously limited set of Evaluation and Management (E&M) services to include all covered professional services, providing a more accurate and inclusive measure of each clinician’s APM engagement.
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