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2021 MIPS Hardship Applications Open

CMS Hardship MIPS 2021 applications

The Centers for Medicare and Medicaid Services (CMS) has opened the 2021 MIPS hardship applications.

There are two applications available, the Extreme and Uncontrollable Circumstance (EUC) hardship application and the Promoting Interoperability (PI) exception application. Both applications are available in your HARP account.

Factors CMS Considers in Hardship Applications

CMS reviews applications taking into account both the event circumstances (what happened) and the timing (how long the circumstances impacted you) to assess your ability to collect and/or submit data for each performance category selected in the application.

  • For the Cost and Quality category exceptions, CMS generally expects the circumstance to have lasted for at least 3 months.
  • Because the Improvement Activities (IA) and PI categories have shorter performance periods (only 90 days), CMS expects the circumstances affecting performance or preventing performance in those categories to be more prolonged.

Reweighting Scenarios

One category reweighting scenarios:

Two category reweighting scenarios:

Steps to Apply

If you are a MarsdenAdvisors client, contact your Client Success Manager to complete this process for you, otherwise:

  1. Sign in to your HARP account
  2. Select "Exception Applications" on the left-hand navigation
  3. Select "Add New Exception"
  4. Select either "Promoting Interoperability Hardship Exception" or "Extreme and Uncontrollable Circumstances Exception"
  5. Complete the application at either the individual, group, virtual group, or APM Entity participation level.
    • Note: you must complete the hardship application at the level for which you will report data to MIPS. Group applications will not apply to individual reporters and vice versa
    • Follow these links for more information on PI Hardship Applications (PDF) and EUC Hardship Applications (PDF)
  6. After you submit your application, you will receive a message and an email stating that your application has been successfully submitted and is pending review.
  7. Once your application has been reviewed and a decision has been made, CMS will post the decision to your HARP account. You can also monitor your application status from there.

Important Notes

  • The deadline to submit hardship applications is December 31, 2021 at 8 pm ET.
  • Retain documentation of the hardship for at least six years in case of an audit.
  • Hardships from previous years do not carry forward. You must submit a new application each year in which you experience a hardship.
  • If you are granted a hardship:
    • Do not submit data in the categories for which you received a hardship exception or CMS will score those categories.
    • If you submit data on 2+ MIPS categories, CMS will score you on the reported categories and assign you a 2021 MIPS final score and 2023 payment adjustment.
    • If you submit data on 1 or fewer MIPS categories (such as claims-based Quality reporters), CMS will assign you a 2021 MIPS score equal to the threshold to avoid a penalty.
    • If you get a hardship for all categories, CMS will assign you a score equal to the threshold to avoid a penalty.

Next Steps

  • Share this information with your practice colleagues.
  • Contact your MarsdenAdvisors Client Success Manager if you plan on applying for a hardship. Your Client Success Manager will submit the application and retain the necessary documentation on your behalf.


If you have any questions on this, let us know! 

Jessica Peterson

Written by Jessica Peterson

Jessica Peterson, MD, MPH is the Vice President of Health Policy at the consulting firm MarsdenAdvisors.

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