MIPS Hardship Exception Due to COVID-19 Continues in 2023

In April 2023, CMS announced it will continue to allow physicians and group practices to apply for a Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances hardship exception to avoid up to a -9% MIPS penalty in 2025 based on 2023 performance.

The exception is not automatic, and interested physicians and groups must actively request reweighting of one or more MIPS performance categories due to the COVID-19 public health emergency.

Requesting reweighting of all four MIPS performance categories will avoid a MIPS penalty in 2025. CMS expects to release the hardship exception application letter in spring 2023.

This is a big relief for physicians because CMS estimated in the 2023 Medicare Physician Fee Schedule Final Rule that up to one-third of MIPS-eligible clinicians would have received a penalty due to the increasingly stringent requirements to participate in MIPS in 2023. It is also likely that small practices and those serving rural and underserved populations would have been disproportionately impacted by these penalties. We encourage members to be aware and prepared to take advantage of this critical reprieve from up to a -9% penalty due to the COVID-19 public health emergency.

To learn more about the announcement and application process, see the link here.