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MIPS: 2020 Hardship Exception Application Deadline is Extended

There are a number of MIPS critical deadlines coming up end of year, and others in the first part of 2021. The deadline to request re-weighting of any or all MIPS categories  for Extreme and Uncontrollable Circumstances  has just been extended due to the pandemic until February 1, 2021 at 8PM EST. (In ‘normal’ years, that deadline would be December 31st.) If re-weighting of all categories is requested and then granted, this exception is the equivalent of eliminating the requirement to submit MIPS data at all (for performance year 2020).

A separate application for the Hardship Exemption specific to the Promoting Interoperability (PI) category has a deadline which remains unchanged on December 31st. If granted, this would  shift the 25 points of the PI category into the Quality category. Both of these exceptions are for the 2020 performance year, which will affect payments in 2022.

Extreme and Uncontrollable Circumstances Exception(s):

HHS defines these as defined as “rare events entirely outside of your control and the control of the facility in which you practice.”  These circumstances would:

  • Cause you to be unable to collect information necessary to submit for a MIPS performance category;
  • Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the Quality performance category for 3 months), and/or;
  • Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.

Promoting Interoperability Performance Category Hardship Exception:

Your application must cite one of the following specified reasons:

  • You’re a small practice ( A TIN or virtual group with 15 or fewer eligible clinicians.)
  • You have decertified EHR technology
  • You have insufficient Internet connectivity
  • You face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
  • You lack control over the availability of CEHRT

Both exception applications may be accessed after logging into your QPP account here:

Note: Some different rules may apply to APM entities. Check the CMS website at:


Other pertinent MIPS deadlines coming up:

  • December 31 – 2021 virtual group election period closes. Solo practitioners and groups with 10 or fewer clinicians (including at least one MIPS eligible clinician) who want to participate in MIPS as a virtual group for the 2021 performance year must submit their election to CMS.
  • January 4, 2021 – 2020 MIPS performance year data submission window opens.
  • March 1, 2021 – Deadline for CMS to receive 2020 claims for the Quality performance category. Claims must be received by CMS within 60 days of the end of the performance period. Deadline dates vary to submit claims to the MACs . Check with the MACs for more specific instructions.
  • March 31, 2021 – 2020 MIPS performance year data submission window closes.


The final rule for 2021 has just been released. We will post a new article on key impact for performance year 2021 once the 2000+ pages have been digested and analyzed.


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