2025 QPP Exception Applications close today, December 31, 2025, at 8 p.m. ET.

The 2025 Quality Payment Program (QPP) Exception applications will close today, December 31, 2025, at 8 p.m. ET. There are 2 types of exception applications that allow users to indicate the reason they’re unable to report data for one or more Merit-based Incentive Payment System (MIPS) performance categories.

MIPS Promoting Interoperability Performance Category Hardship Exception Application

Individual clinicians, groups, and virtual groups (or a third-party representative) 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 Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/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.

MIPS Extreme and Uncontrollable Circumstances Exception Application

Individual clinicians, groups, and virtual groups (or a third-party representative) 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.

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

Alternate Payment Model (APM) Entities can submit applications as well, but they must apply for all performance categories.

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.  We’ll score any qualifying data you, or someone on your behalf, submits and those performance categories will contribute to your final score.

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” from the left-hand navigation.
• Click “Add New QPP Exception” on the right side of the screen.
• Choose your exception type.

Additional Resources

• Quality Payment Program Access User Guide  (ZIP, 5 MB) – Refer to “Step 1: Register for a HARP Account”
• https://qpp.cms.gov/eligibility-participation/eligibility/exceptions?py=2026 (QPP Exceptions: Hardship and Extreme and Uncontrollable Circumstances Applications)

2026 Merit-based Incentive Payment System (MIPS) Performance Year Virtual Group Election Period Closes Today, December 31, 2025 at 11:59 p.m. ET

If you’re interested in forming a virtual group for the 2026 MIPS performance year ,the election period is open. To form a virtual group, an election must be submitted to CMS via email at MIPS_VirtualGroups@cms.hhs.gov no later than today , December 31, 2025 by 11:59 p.m. ET.

Is a Virtual Group Required to Submit an Election to Participate in MIPS for the 2025 MIPS Performance Year?

Yes, a virtual group must submit an election to CMS for each performance year it intends to participate in MIPS as a virtual group. Refer to § 414.1315.

If your virtual group was approved for the 2024 MIPS performance year and intends to participate in MIPS as a virtual group for the 2025 MIPS performance year, your virtual group must still submit an election to CMS for the 2025 MIPS performance year between October 1, 2024, and December 31, 2025, 11:59 p.m. ET.

What is a Virtual Group?

A virtual group is a combination of 2 or more Taxpayer Identification Numbers (TINs) consisting of:

• Solo practitioners (defined as the only clinician in a practice) who are MIPS eligible; and/or
• Groups that have 10 or fewer clinicians (at least one clinician within the group must be MIPS eligible). A group is considered to be an entire single TIN.

A virtual group has the flexibility to determine its own makeup.

A solo practitioner or group can only participate in one virtual group during the performance year.

How Can I Benefit from Participating in a Virtual Group?

You can:   

• Collaborate, share resources, and potentially increase your performance under MIPS.
• Increase performance volume so you can be reliably measured.

What is the Virtual Group Election Process?

A virtual group must do the following prior to submitting an election:

• Establish a formal written agreement between each TIN within the virtual group (see Agreement Sample Template in the 2026 MIPS Virtual Group Election Process Guide within the 2026 MIPS Virtual Group Toolkit (ZIP, 2 MB) .
• Identify an official virtual group representative.

The following elements must be included in an election:

• Acknowledge that a formal written agreement has been established between each TIN within the virtual group.
• The name and contact information for the official virtual group representative.
• The name and TIN for each practice, and all associated National Provider Identifiers (NPIs) under each TIN.

Once the above is complete, the virtual group must submit the election to CMS via email at MIPS_VirtualGroups@cms.hhs.gov   no later than today, December 31, 2024 by 11:59 p.m. ET (see Election Email Sample in the 2026 MIPS Virtual Group Election Process Guide within the 2026 MIPS Virtual Group Toolkit (ZIP, 2 MB) .

Please note that the 2026 MIPS Virtual Group Toolkit (ZIP, 2 MB) contains additional helpful information regarding virtual group participation in MIPS, virtual group reporting requirements, the election process, checklists for virtual groups to consider, and sample templates.