Appendix H 2025 MIPS Promoting Interoperability Hardship Exception

OMB control number: 0938-1314
Expiration Date: 02/28/2027

Merit-based Incentive
Payment System (MIPS)
2025 MIPS Promoting Interoperability
Performance Category Hardship
Exception Application Guide

Table of Contents
How To Use This Guide

3

MIPS Promoting Interoperability Performance Category Hardship
Exception Application Overview

5

MIPS Promoting Interoperability Performance Category Hardship
Exception Information

8

MIPS Promoting Interoperability Performance Category Hardship
Exception: Frequently Asked Questions

15

MIPS Promoting Interoperability Performance Category Hardship
Exception: Application Steps

17

Help and Version History

33

Appendices

36

Purpose: This guide will provide
general information about the MIPS
Promoting Interoperability
Performance Category Hardship
Exception application and provide
step-by-step instructions on how to
complete the application.

Already know what MIPS is? Skip
ahead by clicking the links in the Table
of Contents.

2

How to Use This
Guide

OVERVIEW

How to Use This Guide

Table of Contents
Please Note: This guide was prepared for
informational purposes only and isn't intended
to grant rights or impose obligations. The
information provided is only intended to be a
general summary. It isn't intended to take the
place of the written law, including the
regulations. We encourage readers to review the
specific statutes, regulations, and other
interpretive materials for a full and accurate
statement of their contents.

The Table of Contents is interactive. Click on a
Chapter in the Table of Contents to read that
section.
You can also click on the icon on
the bottom left to go back to the Table of
Contents.

Hyperlinks
Hyperlinks to the Quality Payment Program
website are included throughout the guide
to direct the reader to more information and
resources.

4

MIPS Promoting
Interoperability
Performance Category
Hardship Exception
Application Overview

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION APPLICATION OVERVIEW

Overview
What

Who

Why

The Merit-based Incentive Payment System (MIPS) Promoting Interoperability Hardship Exception application allows you to
request your MIPS Promoting Interoperability performance category be reweighted to 0%.
Individual clinicians, groups, and virtual groups reporting via traditional MIPS, MIPS Value Pathways (MVPs), or the Alternative
Payment Model (APM) Performance Pathway (APP) can submit a MIPS Promoting Interoperability Hardship Exception
application.
• Third party intermediaries can submit an application with permission from the clinician or practice.
• APM Entities can't submit an application at the APM Entity level.
If you qualify for automatic reweighting, you don't need to apply for a MIPS Promoting Interoperability Hardship Exception.
• See Appendix A for information about the clinicians, groups, and virtual groups that automatically qualify for reweighting of
this performance category.
You can submit an application to have your MIPS Promoting Interoperability performance category reweighted to 0% if:
• You have insufficient Internet connectivity.
• You have decertified electronic health record (EHR) technology (decertified under the Assistant Secretary for
Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/ONC) Health IT
Certification Program).
• You lack control over the availability of certified EHR technology (CEHRT).
o Simply lacking CEHRT functionality that meets ASTP/ONC Health IT certification criteria in 45 CFR 170.315 doesn't qualify
as a reason to submit an exception application.
• You face extreme and uncontrollable circumstances such as a disaster, practice closure, severe financial distress or vendor
issues.
o If you experience an extreme and uncontrollable circumstance that impacts multiple performance categories, the Extreme
and Uncontrollable Circumstances Exception application may be more suitable for your given circumstance.

Note: We automatically reweight Promoting Interoperability for small practices. See page 9 for more information.

6

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION APPLICATION OVERVIEW

Overview (Continued)

When

Where

How

The MIPS Promoting Interoperability Hardship Exception application will close on December 31, 2025, at 8 p.m. ET .
Sign in to the Quality Payment Program (QPP) website with your HCQIS Access and Roles Profile (HARP) account.
• For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User
Guide (ZIP, 4MB).
• Representatives of Medicare Shared Savings Program ACOs with a QPP Security Official or QPP Staff User role in the ACO
Management System (ACO-MS) can access the QPP website using their ACO-MS Username and Password.
1. Register for a HARP account.
4. Select 'Add New Exception.'
2. Sign in to the QPP website.
5. Select 'Promoting Interoperability Hardship Exception.'
3. Select 'Exceptions Application' on the left-hand
6. Complete the application for individual, group, or virtual group
navigation.
participation.

See Appendix B (traditional MIPS) and Appendix C (APP) for more information on performance category reweighting.

7

MIPS Promoting
Interoperability
Performance Category
Hardship Exception
Information

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION INFORMATION

Overview
You may automatically qualify for reweighting in this performance category.
• See Appendix A.
• If you automatically quality for reweighting, you don't need to submit a MIPS Promoting Interoperability Hardship Exception application.

You'll complete the MIPS Promoting Interoperability Hardship Exception application at the level for which you'll report data to MIPS for other
performance categories.
• If you're reporting data at the individual level, complete the Hardship Exception application at the individual level.
• If you're reporting data at the group level, complete the Hardship Exception application at the group level.
• Note, a group Hardship Exception application will only apply at the group level.
o If clinicians in your practice participate in MIPS at the individual level, don't complete the Hardship Exception application at the
group level. You'll complete the Hardship Exception application at the individual level for each clinician (who doesn't automatically
qualify for reweighting) to be considered for reweighting.
o If you're reporting an MVP as a subgroup, an approved group level MIPS Promoting Interoperability Hardship Exception will apply to
the subgroup participants.
Did You Know? Subgroups can't submit a MIPS Promoting Interoperability Hardship Exception application at the
subgroup level, but a subgroup will inherit any reweighting approved for their affiliated group.
You can still submit data for the MIPS Promoting Interoperability performance category.
• If your circumstances change and you're able to collect and submit Promoting Interoperability data, we'll disregard your Hardship
Exception application and you'll be scored in this performance category.
• A qualifying data submission will void a hardship exception and cancel automatic reweighting, and you'll be scored in this performance
category. A qualifying data submission includes all required performance data, required attestation statements, CEHRT ID, and the start
and end date for the performance period.

Reminder: Small practices qualify for automatic reweighting of the Promoting Interoperability performance category.

9

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION INFORMATION

Overview (Continued)
You aren't required to submit documentation with your application.
• However, clinicians, groups, and virtual groups should retain documentation of their circumstances supporting their application
for their own records in the event they're selected by CMS for data validation or audit. See the 2025 MIPS Data Validation
Criteria (ZIP, 2MB) for details on the data validation process.
You can apply for a MIPS Promoting Interoperability Hardship Exception if you switch CEHRT vendors during the performance period.
• You would indicate an extreme and uncontrollable circumstances hardship exception and select vendor issues within the
application.
The following circumstances qualify as extreme and uncontrollable circumstances for a MIPS Promoting Interoperability Hardship
Exception:

• A natural disaster resulting in damage to or destruction of your CEHRT.
• Practice closure.
• Severe financial distress resulting in bankruptcy or debt restructuring.
• Vendor issues (such as a change in vendors during the performance period or errors with your CEHRT that your vendor is
unable to address).
You may still be able to report if your EHR product is decertified under the ASTP/ONC Health IT Certification Program during the
2025 performance year.
• You can submit your Promoting Interoperability performance category measures collected in your now-decertified EHR
product if your performance period ended before the decertification occurred.
• If your performance period ended after the EHR decertification occurred, you can apply for a MIPS Promoting Interoperability
Hardship Exception and select decertified EHR technology.
10

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION INFORMATION

Groups and Virtual Groups
To submit an application on behalf of a group, every office location/practice site within the taxpayer identification
number (TIN) must experience the hardship for the group to qualify for the MIPS Promoting Interoperability
Hardship Exception.

• For example, if one office location is within a broadband availability area but the other office(s) for the
practice is not, the office with broadband availability would not qualify for the MIPS Promoting
Interoperability Hardship Exception and must report for those clinicians for whom they have data.
To submit an application on behalf of a virtual group, every office location/practice site for each TIN within the
virtual group must experience the hardship for the virtual group to qualify for the MIPS Promoting
Interoperability Hardship Exception.
• For example, if one TIN is within a broadband availability area but the other TIN(s) in the virtual group is not,
the TIN with broadband availability would not qualify for the MIPS Promoting Interoperability Hardship
Exception and must report for those clinicians for whom they have data.

11

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION INFORMATION

MIPS APM Participants
MIPS eligible clinicians and groups participating in a MIPS APM can apply for a MIPS Promoting Interoperability
Hardship Exception and qualify for automatic reweighting.
If you're participating in MIPS at the APM Entity level (either reporting traditional MIPS or the APP), you can
complete the MIPS Promoting Interoperability Hardship Exception application as an individual or group.
• APM Entities reporting the APP or traditional MIPS can't submit a MIPS Promoting Interoperability Hardship
Exception application on behalf of the entire APM Entity.
• If approved, the MIPS eligible clinician will receive the APM Entity's score but will be excluded from the
calculation when we create an average Promoting Interoperability performance category score for the APM
Entity.
A MIPS Promoting Interoperability Hardship Exception doesn't exempt you from reporting on any CEHRT activities
as may be required by your APM Entity.

Reminder: The Promoting Interoperability Performance Category Hardship Exception application isn't available
to APM Entities.

12

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION INFORMATION

Medicare Shared Savings Program
Unless excluded, for performance years beginning on or after January 1, 2025, an ACO participant, ACO provider/supplier, and
ACO professional that is a MIPS eligible clinician, Qualifying APM Participant (QP), or Partial Qualifying APM Participant (Partial
QP) must:
• Report the MIPS Promoting Interoperability performance category measures and requirements to MIPS at the individual,
group, virtual group, or APM Entity level (i.e., ACO reports on behalf of its clinicians); and

• Earn a performance category score for the MIPS Promoting Interoperability performance category at the individual, group,
virtual group, or APM Entity level.
This requirement applies regardless of the Shared Savings Program track in which the ACO participant, ACO provider/supplier, or
ACO professional participates. For more information, please refer to the Frequently Asked Questions on the Shared Savings
Program Requirement to Report Objectives and Measures for the MIPS Promoting Interoperability Performance Category.

These ACO participants, ACO providers/suppliers, and ACO professionals can apply for hardship exceptions and qualify for automatic
reweighting just like other MIPS eligible clinicians.

Note: APM Entities, including ACOs, can't submit an application at the APM Entity level. You can complete the MIPS
Promoting Interoperability Hardship Exception application as an individual or group. If approved, the MIPS eligible clinician
will receive the APM Entity's score.

13

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION INFORMATION

Medicare Shared Savings Program (Continued)
An ACO participant, ACO provider/supplier, or ACO professional that meets any of an exclusion DOES NOT need to submit a MIPS
Promoting Interoperability Hardship Exception application. ACOs, including their ACO participants, ACO providers/suppliers, and ACO
professionals that are MIPS eligible clinicians, QPs, or Partial QPs should know their status before submitting a hardship exception
application, which cannot be granted because they are already excluded from reporting the MIPS Promoting Interoperability
performance category. Applicable exclusions include:
• Not exceeding the low volume threshold as set forth in 42 CFR 414.1310(b)(1)(iii).
• An eligible clinician (as defined in 42 CFR 414.1305) who is not a MIPS eligible clinician as set forth in 42 CFR 414.1310(b)(2).
• Reweighting of the MIPS Promoting Interoperability performance category in accordance with 42 CFR 414.1380(c)(2)(i)(C) granted
by CMS based on a significant hardship or other type of exception for a specific performance year. Bases for reweighting include
being, as defined in 42 CFR 414.1305:
o A non-patient facing clinician;
o A hospital-based clinician;
o An Ambulatory Surgery Center (ASC)-based clinician; or

o In a small practice.

Note: An ACO participant, ACO provider/supplier, or ACO professional cannot be excluded from the Shared Savings
Program's requirement to report the MIPS Promoting Interoperability performance category solely based on being a QP or
Partial QP. If a QP or Partial QP meets an exclusion noted above, or is not an eligible clinician, the QP or Partial QP would not
be required to report.

14

MIPS Promoting
Interoperability
Performance Category
Hardship Exception:
Frequently Asked
Questions

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: FREQUENTLY ASKED QUESTIONS

Frequently Asked Questions
Question

Where can I look for a status update on my MIPS Promoting
Interoperability Hardship Exception Application?

Answer

You can monitor your application status in your QPP Account on
the QPP website.
Yes, you can add additional staff or representatives who should
receive notifications about the status of the application.

Can additional staff members access/receive notifications about
the status of the MIPS Promoting Interoperability Hardship
Exception Application?

How can I correct a mistake made on our MIPS Promoting
Interoperability Hardship Exception Application?

In the Additional Access section of the application, provide the
email address(es) of additional staff or representatives who you
would like to receive email notifications.
Please note: the additional staff or representatives must have
HARP credentials to see the application on the QPP website.
If you identify an error with your application, please contact the
Quality Payment Program Service Center by email at
QPP@cms.hhs.gov, by creating a QPP Service Center ticket, or
by phone at 1-866-288-8292 (Monday-Friday,
8 a.m. - 8 p.m. ET).

16

MIPS Promoting
Interoperability
Performance Category
Hardship Exception:
Application Steps

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 1: Sign in to Your QPP Account
With your HARP credentials, sign in to your QPP Account on the QPP
website.
Representatives of Medicare Shared Savings Program ACOs with a QPP
Security Official or QPP Staff User role in the ACO Management System
(ACO-MS) can access the QPP website using their ACO-MS Username and
Password.

If you haven't signed in on the QPP website before, you must register
for an account to obtain your HARP credentials. See the QPP Account
Access Guide (ZIP, 4MB) for information on creating an account.

NOTE: The screenshots included in this Guide are based on the QPP
test environment. Because we are always working to incorporate
feedback and improve the user experience, there may be differences
between the screenshots and what you see on the QPP website.

18

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 2: Navigate to Exceptions Application
Once you're signed into your account, select:
• The Exceptions Application tab in the left-hand navigation menu,
then click + Add New QPP Exception
OR
• The Start an Application quick link on the home page.

You can create and submit
a new exception request
until December 31, 2025,
8 p.m. ET.

NOTE: The screenshots
included in this Guide are
based on the QPP test
environment. Because we
are always working to
incorporate feedback and
improve the user
experience, there may be
differences between the
screenshots and what you
see on the QPP website.

19

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 3: Select Exception Type
Select the MIPS Promoting Interoperability Performance Category Hardship Exception, then click Continue.

NOTE: The screenshots included in this Guide are based on the QPP test environment. Because we are always working to incorporate
feedback and improve the user experience, there may be differences between the screenshots and what you see on the QPP website.
20

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 4: Select Application Type
Select the participation level at which you intend (or intended)
to participate in MIPS, then select Save & Continue.

NOTE: The screenshots included in this Guide are based on the QPP
test environment. Because we are always working to incorporate
feedback and improve the user experience, there may be differences
between the screenshots and what you see on the QPP website.

(Image features application at the individual level)

21

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 5: Enter Participation Level Information
Enter the required participation level
information.

The required information for each
participation level is as follows:
Participation Level
Individual Clinician
Group
Virtual Group

Required Information
• National Provider Identifier
(NPI)
• Practice Affiliation
• Taxpayer Identification
Number (TIN)
• Virtual Group Identifier

NOTE: The screenshots included in this Guide are
based on the QPP test environment. Because we
are always working to incorporate feedback and
improve the user experience, there may be
differences between the screenshots and what you
see on the QPP website.

(Image features application at the individual level)

22

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 6: Enter Submitter Details
Enter your contact information (as the
submitter) and identify your relationship to
the party identified in the application.

NOTE: The screenshots included in this Guide are
based on the QPP test environment. Because we
are always working to incorporate feedback and
improve the user experience, there may be
differences between the screenshots and what you
see on the QPP website.

23

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 7: Enter Additional Staff in Additional Access Section
You can identify additional users to receive notifications about the application in the Additional Access section.
If there's a HARP account associated with the email address(es) you provide, the person will be able to sign in
to their own account on the QPP website and access the application.

NOTE: The screenshots included in this Guide are based on the QPP test environment. Because we are always working to
incorporate feedback and improve the user experience, there may be differences between the screenshots and what you see on
the QPP website.

24

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 8: Select the Reason for the MIPS Promoting Interoperability
Hardship
Select the option that aligns with your reason for submitting a MIPS Promoting Interoperability Hardship
Exception application.
You don't need to submit supporting
documentation with your application.
However, you should retain
documentation of the circumstances
supporting your application for your own
records in case you are selected by CMS
for data validation or an audit. See our
2025 MIPS Data Validation Criteria (ZIP,
2MB) for details on the data validation
process.
NOTE: The screenshots included in this
Guide are based on the QPP test
environment. Because we are always
working to incorporate feedback and
improve the user experience, there may
be differences between the screenshots
and what you see on the QPP website.

25

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 9: Complete Attestation and Provide Event Description
Before submitting your application, you must complete the attestation (differs for each reason option).
• Insufficient Internet Connectivity

• Extreme and Uncontrollable Circumstances
• Lack of Control Over the Availability of CEHRT
• EHR Decertification
You also can provide an optional brief description on the hardship you experienced and how performance data is impacted.

NOTE: The screenshots included in this Guide
are based on the QPP test environment.
Because we are always working to
incorporate feedback and improve the user
experience, there may be differences
between the screenshots and what you see
on the QPP website.

26

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 9: Complete Attestation and Provide Event Description
(Continued)
Reason Option 1: Insufficient Internet Connectivity
Review the attestation statement and select “I attest.”
You can provide an optional description of the hardship
event.

NOTE: The screenshots included in this Guide are based on the
QPP test environment. Because we are always working to
incorporate feedback and improve the user experience, there
may be differences between the screenshots and what you see
on the QPP website.

27

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 9: Complete Attestation and Provide Event Description
(Continued)
Reason Option 2: Extreme and Uncontrollable
Circumstances
Select the Extreme and Uncontrollable
Circumstances Event Type that applies to you, enter
the event dates, then review the attestation
statement and select “I attest.”
You can provide an optional description of the
hardship event.

NOTE: The screenshots included in this Guide are based on
the QPP test environment. Because we are always working
to incorporate feedback and improve the user experience,
there may be differences between the screenshots and
what you see on the QPP website.

28

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 9: Complete Attestation and Provide Event Description
(Continued)
Reason Option 3: Lack of Control Over the
Availability of CEHRT
Review the attestation statement and select “I
attest.”
You can provide an optional description of the
hardship event.

NOTE: The screenshots included in this Guide are based
on the QPP test environment. Because we are always
working to incorporate feedback and improve the user
experience, there may be differences between the
screenshots and what you see on the QPP website.

29

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 9: Complete Attestation and Provide Event Description
(Continued)
Reason Option 4: EHR Decertification
Enter the date that your EHR was decertified
(under ONC's Health IT Certification Program)
and your ONC-ACB Certification ID. Then, review
the attestation statement and select “I attest.”

You can provide an optional description of the
hardship event.

NOTE: The screenshots included in this Guide are based
on the QPP test environment. Because we are always
working to incorporate feedback and improve the user
experience, there may be differences between the
screenshots and what you see on the QPP website.

30

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

Step 10: Submit MIPS Promoting Interoperability Hardship
Exception Application
Once you're done with your application, review
the disclosures, then select Certify & Submit.

NOTE: The screenshots included in this Guide are based
on the QPP test environment. Because we are always
working to incorporate feedback and improve the user
experience, there may be differences between the
screenshots and what you see on the QPP website.

31

MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY
HARDSHIP EXCEPTION: APPLICATION STEPS

MIPS Promoting Interoperability Hardship Exception Application
Submission Confirmation
After you submit your MIPS Promoting
Interoperability Hardship Exception application,
you'll receive a message stating that your
Hardship Exception application has been
successfully submitted and is pending review.
You'll also receive an email notification.
See Appendix D for information on the various
application statuses.

NOTE: The screenshots included in this Guide are based
on the QPP test environment. Because we are always
working to incorporate feedback and improve the user
experience, there may be differences between the
screenshots and what you see on the QPP website.

32

Help and Version
History

HELP AND VERSION HISTORY

Where Can You Go for Help?

Contact the Quality Payment Program Service Center
by email at QPP@cms.hhs.gov, by creating a QPP
Service Center ticket, or by phone at 1-866-288-8292
(Monday through Friday, 8 a.m. - 8 p.m. ET). To
receive assistance more quickly, please consider
calling during non-peak hours—before 10 a.m. and
after 2 p.m. ET.
People who are deaf or hard of hearing can dial 711 to
be connected to a TRS Communications Assistant.

Visit the Quality Payment Program
website for other help and support
information, to learn more about
MIPS, and to check out the resources
available in the Quality Payment
Program Resource Library.

Visit the Small Practices page of
the Quality Payment Program
website where you can sign up
for the monthly QPP Small
Practices Newsletter and find resources
and information relevant
for small practices.

34

HELP AND VERSION HISTORY

Version History
If we need to update this document, changes will be identified here.
D AT E

05/06/2025

DESCRIPTION

Original Posting.

According to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.), no persons are required to respond to a collection of information
unless it displays a valid OMB control number. The valid OMB control number for this information collection is 0938-1314 (Expiration date:
2/28/2027). This information collection is the tool to request that MIPS Promoting Interoperability Hardship Exception applications allow you
to request that your MIPS Promoting Interoperability performance category be reweighted to 0%. The time required to complete this
information collection is estimated to average .25 hours per response, including the time to review instructions, search existing data resources,
gather the data needed, to review and complete the information collection. This information collection is voluntary and all information
collected will be kept private in accordance with regulations at 45 CFR 155.260, Privacy and Security of Personally Identifiable
Information. Pursuant to this regulation, CMS may only use or disclose personally identifiable information to the extent that such information
is necessary to carry out their statutory and regulatory mandated functions. If you have comments concerning the accuracy of the time
estimate(s) or suggestions for improving this form, please write to: CMS, 7500 Security Boulevard, Attn: PRA Reports Clearance Officer, Mail
Stop C4-26-05, Baltimore, MD 21244-1850. If you have questions or concerns regarding where to submit your documents, please contact QPP
at qpp@cms.hhs.gov.
Under the Privacy Act of 1974 (5 U.S.C. 552a) any personally identifying information obtained will be kept private to the extent of the law.

35

Appendices

APPENDICES

Appendix A. Automatic Reweighting in the MIPS Promoting
Interoperability Performance Category
Reason for Reweighting (Individual Clinicians)

You have one of these Special Statuses:
• Small Practice;
• Ambulatory Surgical Center (ASC)-based;
• Hospital-based; or
• Non-patient facing

Reason for Reweighting (Groups and Virtual Groups)

Action Needed by the Individual
None – You're automatically excepted from having to submit data
for this performance category as an individual, though you may still
choose to do so.
You'll be scored in this performance category if your practice is
participating as a group or virtual group and doesn't qualify for
reweighting.
Action Needed by the Group or Virtual Group

You have one of the following Special Statuses:
• ASC-based.
• Small Practice
• Hospital-based: Group or virtual group must have more than
75% of clinicians designated as hospital-based.
• Non-patient facing: Group or virtual group must have more
than 75% of clinicians designated as non-patient facing.

You'll be scored in this performance category if your practice is
participating as a group or virtual group and doesn't qualify for
reweighting.

All of the MIPS eligible clinicians in your group or virtual group
qualify for reweighting as individuals (through any combination of
special statuses or approved MIPS Promoting Interoperability
Hardship Exception).

You'll be scored in this performance category if your practice is
participating as a group or virtual group and doesn't qualify for
reweighting.

37

APPENDICES

Appendix B. MIPS Performance Category Weight Redistribution
Policies Under Traditional MIPS and MVPs Finalized for the 2025
Performance Year: Individual Clinicians, Groups, and Virtual Groups
The table below illustrates the 2025 performance category weights and reweighting policies that CMS will
apply to clinicians, groups, and virtual groups reporting via traditional MIPS or MVPs.

Refer to Appendix D for reweighting
policies that apply to APM Entities.

Important Reminders:
• Individual Clinicians, Groups, Virtual Groups: If fewer than 2 performance categories can be scored (meaning 1 performance
category is weighted at 100%, or all performance categories are weighted at 0%), the clinician, group, or virtual group will
receive a final score equal to the performance threshold and the MIPS eligible clinicians will receive a neutral payment
adjustment in the 2027 payment year.
MIPS Performance Category Reweighting
Scenario

Quality Category
Weight

Cost Category Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

30%

30%

15%

25%

No Cost
(Cost → Quality and Promoting
Interoperability)

55%

0%

15%

30%

No Improvement Activities
(Improvement Activities → Quality)

45%

30%

0%

25%

No Promoting Interoperability
(Promoting Interoperability → Quality)

55%

30%

15%

0%

No Quality
(Quality → Promoting Interoperability)

0%

30%

15%

55%

No Reweighting
Standard Weighting under traditional MIPS
Reweight 1 Performance Category

Note: Small practices have a different performance category weight redistribution
policy than individual clinicians, larger groups, and virtual groups (see Appendix C).

Table continues on next slide.

38

APPENDICES

Appendix B. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS and MVPs Finalized for the 2025 Performance
Year: Individual Clinicians, Groups, and Virtual Groups (Continued)
MIPS Performance Category Reweighting
Scenario

Quality Category
Weight

Cost Category Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

85%

0%

15%

0%

0%

0%

15%

85%

70%

0%

0%

30%

0%

50%

50%

0%

70%

30%

0%

0%

0%

30%

0%

70%

Reweight 2 Performance Categories
No Cost + No Promoting Interoperability
(Cost + Promoting Interoperability →
Quality)
No Cost + No Quality
(Cost + Quality → Promoting
Interoperability)
No Cost + No Improvement Activities
(Cost + Improvement Activities →
Promoting Interoperability + Quality)
No Promoting Interoperability + No Quality
(Promoting Interoperability + Quality →
Cost + Improvement Activities)
No Promoting Interoperability + No
Improvement Activities
(Promoting Interoperability +
Improvement Activities → Quality)
No Quality + No Improvement Activities
(Quality + Improvement Activities →
Promoting Interoperability)

Note: If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final
score, you'll receive a score equal to the performance threshold. See next slide for additional information.

Table continues on next slide.

39

APPENDICES

Appendix B. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS and MVPs Finalized for the 2025 Performance
Year: Individual Clinicians, Groups, and Virtual Groups (Continued)
MIPS Performance Category Reweighting
Scenario

Quality Category
Weight

Cost Category Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

Reweight 3 Performance Categories
If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you'll
receive a score equal to the performance threshold and you'll receive a neutral payment adjustment.
Reweight 4 Performance Categories

If all performance categories are reweighted to 0%, you'll receive a score equal to the performance threshold and you'll receive a neutral payment
adjustment.

40

APPENDICES

Appendix C. MIPS Performance Category Weight Redistribution
Policies Under Traditional MIPS Finalized for the 2025
Performance Year: Small Practices
The table below illustrates the 2025 performance category
weights and reweighting policies that CMS will apply to small
practices.
MIPS Performance Category Reweighting
Scenario

Refer to Appendix D for reweighting policies that apply
to APM Entities reporting the APP. APM Entities
reporting traditional MIPS or MVPs can only request
reweighting for all performance categories.

Quality Category
Weight

Cost Category Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

30%

30%

15%

25%

No Cost
(Cost → Quality and Promoting
Interoperability)

55%

0%

15%

30%

No Improvement Activities
(Improvement Activities → Quality)

45%

30%

0%

25%

No Promoting Interoperability
(Promoting Interoperability → Quality
and Improvement Activities)

40%

30%

30%

0%

No Quality
(Quality → Promoting Interoperability)

0%

30%

15%

55%

No Reweighting

Standard Weighting under traditional MIPS
Reweight 1 Performance Category

Table continues on next slide.

41

APPENDICES

Appendix C. MIPS Performance Category Weight Redistribution
Policies Under Traditional MIPS Finalized for the 2025
Performance Year: Small Practices (Continued)
MIPS Performance Category Reweighting
Scenario

Quality Category
Weight

Cost Category Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

50%

0%

50%

0%

0%

0%

15%

85%

70%

0%

0%

30%

0%

50%

50%

0%

70%

30%

0%

0%

0%

30%

0%

70%

Reweight 2 Performance Categories
No Cost + No Promoting Interoperability
(Cost + Promoting Interoperability →
Quality and Improvement Activities)
No Cost + No Quality
(Cost + Quality → Promoting
Interoperability)
No Cost + No Improvement Activities
(Cost + Improvement Activities →
Promoting Interoperability + Quality)
No Promoting Interoperability + No Quality
(Promoting Interoperability + Quality →
Cost + Improvement Activities)
No Promoting Interoperability + No
Improvement Activities
(Promoting Interoperability +
Improvement Activities → Quality)
No Quality + No Improvement Activities
(Quality + Improvement Activities →
Promoting Interoperability)

Note: If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score,
you'll receive a score equal to the performance threshold and you'll receive a neutral payment adjustment.

42

APPENDICES

Appendix D. MIPS Performance Category Weight Redistribution
Policies for APM Entities and the APP Finalized for the 2025
Performance Year
The table below illustrates the 2025 performance category weights and reweighting policies that apply to individual clinicians, groups, and
APM Entities reporting via the APP.
Reminders:
• The cost performance category weight is zero percent for clinicians scored through the APP.
• There are no reporting requirements for the improvement activities performance category under the APP for the 2025 performance
year. Participants reporting via the APP will automatically receive full credit for the improvement activities performance category for
the 2025 performance year.
• MIPS participants reporting via the APP will follow the same reporting requirements as traditional MIPS for the Promoting
Interoperability performance category.
MIPS Performance Category Reweighting Scenario
under the APP

Quality Category
Weight

Cost Category
Weight

Improvement Activities
Category Weight

Promoting Interoperability
Category Weight

50%

0%

20%

30%

75%

0%

25%

0%

0%

0%

25%

75%

No Reweighting
Standard Weighting under the APP
Reweight 1 Performance Category
No Promoting Interoperability
(Promoting Interoperability → Quality)
No Quality
(Quality → Promoting Interoperability)
Reweight 2 + Performance Categories
If you have multiple performance categories reweighted to 0% so that a single performance category is weighted at 100% of your final score, you'll
receive a score equal to the performance threshold and you'll receive a neutral payment adjustment.
43

APPENDICES

Appendix E. MIPS Promoting Interoperability Hardship Exception
Application Status Descriptions
The table below provides a description of each application status in the order of which they occur.
Draft in Progress

Submitted – Pending Approval

Approved / Denied

We completed our review of your
application and approved your
request.
You're currently working on your
application and haven't
submitted it yet.
Select Manage to continue
working on your application.

You've successfully completed
and submitted your application.
Applications are reviewed in the
order of which they're received.
We completed our review of your
application and denied your
request.

Withdrawn

You've withdrawn your
application. You can withdraw
your application at any point in
the process.
An application can't be reopened
after being withdrawn. You'll
need to complete a new
application.

44