The 2026 MIPS Exception Window Closes December 31. A Hard Year Does Not Have to Cut Your 2028 Medicare Pay.

Most practices think about MIPS in the first quarter, when data is submitted. The decision that can protect a bad year has an earlier deadline. CMS's 2026 Extreme and Uncontrollable Circumstances (EUC) exception application closes on December 31, 2026, at 8 p.m. ET, and the Promoting Interoperability hardship exception application runs to the same date.

The stakes are set in rules already final. The 2026 performance year maps to the 2028 MIPS payment year. CMS has set the performance threshold at 75 points through the 2028 performance year, and the maximum negative payment adjustment is 9%. A practice that falls well short in 2026 carries that result into its Medicare Part B payments two years later.

What the EUC exception covers

CMS's 2026 application guide describes events such as a natural disaster, a ransomware, malware or cyberattack, or a public health emergency that kept a practice from collecting data for an extended period or could affect its cost performance. The key points from the guide:

• Individual clinicians, groups, virtual groups and APM Entities can apply. A third-party intermediary can submit with the practice's permission. Subgroups cannot apply on their own; they inherit their group's result.
• You can ask for 0% weighting in any of the four categories: quality, cost, improvement activities and Promoting Interoperability. APM Entities must request all four.
• If all categories are reweighted, or fewer than two categories are left to score, the final score equals the performance threshold and the payment adjustment in 2028 is neutral.
• Data overrides an approved exception, category by category. If you, or a vendor or registry on your behalf, submit qualifying data for a category, that category is scored. Cost is the exception: if cost is in your approved application, it's not scored.

That last point is where practices lose the benefit. A registry or EHR vendor that submits quality data by default can undo the reweighting the practice applied for. Tell every vendor that reports for you what was approved.

The automatic exception does not cover groups

CMS also applies an automatic EUC policy to clinicians whose practice address in PECOS is in an area hit by a FEMA-designated major disaster or public health emergency during the year. For 2026, CMS's fact sheet lists areas in the Northern Mariana Islands (Super Typhoon Sinlaku) and certain counties in Hawaii (Kona Low weather systems).

The automatic policy applies only to clinicians reporting as individuals. It does not apply to group, subgroup, virtual group or APM Entity participation. A group that reports together and was affected by a disaster or a cyberattack needs to apply.

Last year's results are already public

In its September 17, 2026 MLN Connects newsletter, CMS said 2024 Quality Payment Program performance information has been added to the Provider Data Catalog and to clinician and group profile pages on Medicare.gov Care Compare. The 2024 performance year is the one that set 2026 payment adjustments. An industry analysis by Healthmonix put that range at up to +1.05% for a perfect score and -9% for a score of 10 or below.

So this quarter is a good time to look at both years together: what patients and referring physicians can see about 2024, and what 2026 is on track to produce.

A December checklist for practices in MIPS

A short review before year-end covers most of the risk:

• Confirm which clinicians in the practice are MIPS eligible for 2026 and whether you report as individuals, a group or through an APM Entity.
• Write down any event in 2026 that stopped data collection for a real stretch of time: a cyberattack, an EHR outage, a disaster, a building closure. Note the dates and the systems affected.
• If an event qualifies, submit the EUC application on the QPP website before December 31, 2026 at 8 p.m. ET, and keep a copy of the approval.
• If your EHR wasn't certified, or you had another Promoting Interoperability barrier, review the Promoting Interoperability hardship exception before the same date.
• Tell your EHR vendor, registry or billing partner which categories were reweighted, so nothing is submitted for those categories by default.
• If you're not applying, check that your quality measures have enough data to meet completeness requirements before December 31, while there's still time to fix a gap.
• Look up your 2024 results on Care Compare and compare them with your 2026 progress.

This is general information, not legal or compliance advice. CMS decides each application, and the QPP website has the current forms and guidance.

Keep MIPS on the revenue calendar

MIPS is easy to treat as a reporting chore, but its result is a payment adjustment on every Medicare Part B claim two years later. VOSKPO helps practices keep deadlines like this one on the same calendar as their claims work. A revenue review can show where reporting and billing gaps touch a practice's Medicare payments.