The Centers for Medicare and Medicaid Services (CMS) said the 2026 Quality Payment Program (QPP) exception applications are available now through Dec. 31.

CMS said there are two types of exception applications that allow participants to indicate why they can’t report data for one or more Merit-based Incentive Payment System (MIPS) performance categories.

1 - MIPS Promoting Interoperability Performance Category Hardship Exception Application

Individual clinicians, groups, and virtual groups (or their third-party representative) reporting traditional MIPS, a MIPS Value Pathways (MVP), or the Alternative Payment Model (APM) Performance Pathway (APP) can submit a MIPS Promoting Interoperability Performance Category Hardship Exception application for the following reasons:

• You have decertified Electronic Health Record (EHR) technology (must be decertified under the Office of the National Coordinator for Health Information Technology (ONC) Health IT Certification Program).

• You have insufficient internet connectivity.

• You face extreme and uncontrollable circumstances such as a disaster, practice closure, severe financial distress, or vendor issues.

• You lack control over the availability of certified EHR technology (CEHRT).

This application is specific to the MIPS Promoting Interoperability performance category. If your application is approved, you won’t be required to report data for this performance category, CMS said.

REMINDERS: Small practices, non-patient facing, hospital-based clinicians, and ambulatory surgical center-based clinicians are automatically excepted from having to report data for the Promoting Interoperability performance category.

APM Entities reporting the APP or traditional MIPS can’t submit a MIPS Promoting Interoperability Performance Category Hardship Exception application on behalf of the entire APM Entity.

2 - MIPS Extreme and Uncontrollable Circumstances Exception Application

Individual clinicians, Groups, and Virtual groups

Individual clinicians, groups, and virtual groups (or their third-party representative) reporting traditional MIPS, an MVP, or the APM Performance Pathway can submit a MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application for one or more MIPS performance categories (quality, cost, improvement activities, and Promoting Interoperability) due to extreme and uncontrollable circumstances, defined as rare events entirely outside of your control and the control of the facility in which you practice.

CMS said 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 three months).

• Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.

“If your application is approved, you won’t be required to report data for the performance category or categories included in your approved application. However, please note that a qualifying data submission will override approved reweighting on a category-by-category basis,” CMS said. “Any qualifying data you or someone on your behalf submits will be scored, and those performance categories will contribute to your final score.”

Alternative Payment Model Entities

Alternative Payment Model (APM) Entities including Medicare Shared Savings Program (Shared Savings Program) Accountable Care Organizations (ACOs) can also submit applications, but they must apply for all performance categories. If your application is approved, you won’t be required to report data for MIPS, and any data submitted won’t be scored for purposes of MIPS.

How to Apply?

To submit either exception application:

• Sign in to the QPP website with your Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) account.

• Choose “Exceptions Application.”

• Click “Add New QPP Exception.”

• Choose your exception type.

  
  

Additional Resources

• Quality Payment Program Access User Guide – Refer to “Step 1: Register for a HARP Account”

• Exception Applications (webpage on the QPP website)

• 2026 MIPS Promoting Interoperability Hardship Exception Application Guide

• 2026 MIPS Extreme and Uncontrollable Circumstances Exception Application Guide

• 2026 MIPS Automatic Extreme and Uncontrollable Circumstances Policy Fact Sheet