Reminder: Apply for 2023 MIPS Hardship Exemption by Jan. 2
By Emma Freer

Physicians eligible to participate in Medicare’s Merit-Based Incentive Payment System (MIPS) may be spared a steep financial penalty, continuing a trend seen throughout the COVID-19 pandemic.  

In the meantime, the Texas Medical Association continues to advocate for legislative improvements to the increasingly complex quality payment program. 

Due to the pandemic, the Centers for Medicare & Medicaid Services (CMS) again allowed clinicians and groups to apply for MIPS relief in the 2023 performance year under its “extreme and uncontrollable circumstances” and "promoting interoperability performance category" exceptions. Applications close at 7 pm CT on Jan. 2, 2024.

Applicants may request reweighting of one or more MIPS performance categories via their Quality Payment Program account. Those granted an exception will avoid a payment penalty of up to 9% in the 2025 payment year.  

Robert Bennett, TMA’s vice president of medical economics, says this news will come as a relief to many physicians whose practice viability has been threatened by inflation, a tight labor market, and other economic headwinds.  

“This is going to protect the majority of practices from [experiencing] cuts, saving them and acknowledging the hardship of the pandemic,” he told Texas Medicine Today

CMS estimates as many as one-third of MIPS-eligible clinicians would be penalized in the 2023 performance year due to the program’s increasingly onerous reporting requirements, with the burden falling most heavily on small and rural practices and those caring for underserved populations, according to the American Medical Association. 

Eligible participants who would have incurred a payment penalty without the hardship exception won’t be penalized in 2025 for their 2023 performance. Those who have achieved success in MIPS – meaning they have met the performance threshold of 75 points – still will be eligible for incentive payments of up to 9%. However, Congress has designated MIPS as a budget-neutral program, so any incentives are doled out in proportion to penalties assessed.  

This isn’t the first time CMS has invoked the “extreme and uncontrollable circumstances” policy. Since MIPS’ launch in 2017, the federal agency has done so for hurricanes, wildfires, and the pandemic. 

Mr. Bennett says TMA continues to work with others in organized medicine and Congress to improve MIPS, including by advocating for reforms to CMS’ reporting process so that participating physicians can access their MIPS scores and feedback in a timely – and therefore actionable – manner.  

For details and qualifications on the 2023 MIPS exceptions, visit CMS' information and application webpage.


Last Updated On

November 28, 2023

Originally Published On

April 25, 2023

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Emma Freer

Associate Editor

(512) 370-1383

Emma Freer is a reporter for Texas Medicine. She previously worked in local news, covering city politics, economic development, and public health. A native Clevelander, she graduated from Columbia Journalism School and the University of St. Andrews.

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