An exception is a specific application, not a backup plan for ordinary delays.
“We can always file a hardship exception” is a risky sentence to hear in a year-end reporting meeting.
Before anyone relies on that option, your practice needs to establish what happened, how it affected MIPS participation, and which exception actually fits. A difficult reporting year alone does not answer those questions.
I recommend starting with the evidence rather than the application. That means reviewing the event timeline, the reporting work it disrupted, and the records supporting your explanation. This approach helps you distinguish a potentially qualifying circumstance from an operational problem that still needs correction.
For 2026, the MIPS Extreme and Uncontrollable Circumstances exception application closes December 31, 2026, at 8 p.m. ET. That is the application deadline, not a reason to postpone the review.
Understand What a MIPS EUC Exception Addresses
EUC means Extreme and Uncontrollable Circumstances. CMS describes these as rare events beyond the clinician's and the facility's control. Qualifying circumstances can prevent necessary data collection, impede submission for an extended period, or disrupt operations in ways that affect cost measures and other administrative claims-based measures.
The practical question is specific:
What did this event prevent your practice from doing?
“We experienced a cyberattack” identifies an event. Your review should also establish which records became unavailable, which clinicians or locations were affected, and how long the disruption continued.
Avoid starting with the score you want to avoid. Start with the work you could not perform and the evidence explaining why.
Separate EUC From a Promoting Interoperability Hardship Exception
People often use “MIPS hardship exception” as a general label. However, the EUC application and the Promoting Interoperability hardship exception serve different purposes.
| Application | What it addresses |
|---|---|
| MIPS EUC exception | Requests relief for affected MIPS performance categories under EUC criteria |
| Promoting Interoperability hardship exception | Requests reweighting specifically for the Promoting Interoperability category |
CMS identifies PI hardship reasons, including decertified EHR technology, insufficient internet connectivity, certain extreme circumstances, and lack of control over certified EHR availability. Approval is required. Some participants already qualify for automatic PI reweighting based on their status.
I would confirm the practice’s participation status before drafting either application. Then identify the problem and the appropriate route.
A PI-specific problem should not automatically become a request to remove every MIPS category.
Distinguish an External Disruption From an Ordinary Delay
An overdue task and an uncontrollable event can both produce an incomplete reporting file. They require different responses.
Consider these questions:
Did the event make data unavailable, or has nobody requested the export?
Was the reporting system inaccessible, or was access never arranged?
Did an external event interrupt operations, or did responsibility remain unclear?
What work could the practice still complete during the disruption?
These are review questions, not automatic eligibility tests.
A particularly important safeguard concerns vendors. CMS’s EUC application guide says the policy does not cover a third-party intermediary simply being unable to submit on a clinician’s behalf. It distinguishes that situation from events affecting the clinician’s ability to collect and provide data.
“The registry missed our submission” therefore needs investigation and appropriate escalation. It should not become an assumed EUC strategy.
Build a Timeline Someone Else Can Follow
Chirpy Bird recommends creating a short chronology before writing the application narrative.
Record the event’s start, discovery, operational impact, recovery milestones, and any continuing limitations. Those dates may differ.
For example, restoring system access does not necessarily establish that historical records were recovered or reporting feeds reconciled. Explain those distinctions accurately.
Your chronology should answer:
When did the problem begin? What stopped working? What recovered? What remained unavailable?
Assign each statement a supporting source, such as an incident ticket, closure notice, or recovery report.
This exercise also exposes contradictions early. If the IT record shows access restored in September while the draft says systems remained unavailable through December, resolve that difference before submission.
Do not make the narrative more dramatic. Make it easier to verify.
Retain Evidence That Explains the Reporting Impact
CMS does not require supporting documents with the EUC application, but it instructs applicants to retain documentation for possible validation or audit.
My recommended working file includes:
| Evidence | What it helps establish |
|---|---|
| Incident reports and service tickets | What happened and when |
| System availability or restoration records | Duration and extent of access problems |
| Practice closure or emergency notices | Operational interruption |
| Vendor correspondence | Known limitations and recovery attempts |
| Data reconciliation results | What remains missing or unreliable |
| Internal decision notes | Who reviewed the facts and approved next steps |
These are practical examples, not a universal CMS attachment checklist.
Keep relevant records in a secure location. Avoid collecting unnecessary patient information merely to make the file look substantial.
The strongest evidence connects the event to the reporting limitation. A large folder of unrelated correspondence does not make that connection for you.
Review Each MIPS Category Separately
For individuals, groups, and virtual groups, an EUC request can address one or more categories. An approved category is reweighted to zero; categories outside the approval remain subject to applicable scoring rules.
Before selecting categories, use this internal worksheet:
| Category | Question to investigate |
|---|---|
| Quality | Which measure data became unavailable or unreliable? |
| Promoting Interoperability | Which technology-dependent requirements could the practice not meet? |
| Improvement Activities | Which planned activities or supporting records did the event disrupt? |
| Cost | How did the disruption change care delivery or operations relevant to claims-based evaluation? |
Give each requested category its own explanation. Do not copy the same broad sentence into every section.
For cost, “our spending was higher” isn't enough. Identify the operational change and its connection to the event.
Then ask your reporting specialist to calculate the remaining category weights. Removing one category can change how much the others matter.
Match the Application to the Reporting Level
Your review should identify whether the practice intends to participate as an individual, group, virtual group, subgroup, or APM Entity.
CMS distinguishes these routes. Group-wide circumstances can support a group application; circumstances affecting only certain clinicians may require individual applications. Subgroups inherit applicable reweighting from their affiliated group rather than applying independently.
For practice managers, this means checking identifiers and scope before someone clicks submit.
Does the application describe the same organization, clinicians, and reporting arrangement as the underlying evidence?
APM Entities require a separate review. CMS requires an all-category request and a PI eligibility condition involving at least 75% of the Entity’s MIPS-eligible clinicians. Its submission-override rules also differ.
ACO leaders should also examine their model-specific obligations. Do not assume a MIPS decision resolves every ACO reporting requirement.
Coordinate Submissions After Approval
An approved exception should trigger a conversation with every party authorized to submit data.
For individual, group, and virtual group applications, qualifying submissions can override approved reweighting for the submitted category. Approved cost reweighting differs because the category does not involve participant data submission.
Ask your registry, EHR reporting team, and internal coordinator:
What data have you already submitted?
What additional submissions are scheduled?
Who approves a change to that schedule?
Where will we document the reporting decision?
Do not instruct a vendor to stop everything without reviewing the implications. Equally, do not let an automated submission proceed simply because it was scheduled months earlier.
Keep the CMS decision beside the submission plan, so both reflect the same understanding.
Verify Automatic Relief Rather Than Assuming It
CMS also has an automatic EUC policy for certain individual clinicians affected by designated events.
That policy does not automatically extend to group, subgroup, virtual group, or APM Entity participation. Participation and submitted data can change the scoring outcome. A disaster declaration alone should not end your review.
Confirm the applicable CMS designation, the clinician’s participation information, and the reporting arrangement involved. Record what you checked and when.
If your circumstances do not fit the published guidance clearly, seek clarification. A written question with dates and a concise description is more useful than asking whether your practice “probably qualifies.”
Set an Internal Deadline Before December 31
The 2026 MIPS EUC application deadline is December 31, 2026, at 8 p.m. ET.
I recommend working backward from that cutoff:
Assign a person to coordinate the eligibility review.
Complete the timeline and evidence file.
Review category and participation-level implications.
Verify account access and submit the application.
Save the confirmation, monitor the decision, and update the reporting plan.
Choose an internal submission date that leaves room for questions and corrections. Holiday absences and account-access problems are easier to manage before the final afternoon.
Treat submission and approval as separate milestones. The person who files should also know who will check the outcome.
Review Exception Eligibility Before Relying on Relief
An evidence-first MIPS hardship exception review begins with a clear account of the disruption. It links that event to the affected reporting work, identifies the appropriate application, and assesses what happens to the remaining categories.
I would rather see a practice resolve an eligibility question early than build its entire year-end plan around an untested assumption. The review may support an application. It may instead reveal reporting work that remains achievable and needs immediate attention.
Contact Chirpy Bird to review exception eligibility. Bring your event timeline, participation details, and current reporting status so we can discuss the appropriate next step.
Review MIPS hardship exception and EUC eligibility with Chirpy Bird.
