CMS Reopens MIPS Hardship Applications Following AMA Advocacy on IV Fluid Shortage
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In response to sustained advocacy from the American Medical Association (AMA), the Centers for Medicare & Medicaid Services (CMS) has agreed to reopen the 2024 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances (EUC) Exception Application window. This allows physicians affected by the ongoing national intravenous (IV) fluid shortage to avoid up to a -9% MIPS penalty on their 2026 Medicare payments.
The IV fluid shortage—exacerbated by Hurricane Helene and a severe winter respiratory illness season—has significantly strained supply chains and impacted patient care delivery. Recognizing these conditions, CMS will accept new EUC applications from March 31 through April 14, 2025, at 8:00 p.m. ET. The hardship exception applies solely to the IV fluid shortage; applications citing other reasons will be denied.
Physicians are advised to request reweighting for all four MIPS categories: quality, cost, promoting interoperability, and improvement activities. CMS will not reweight any category for which data has already been submitted. However, if three categories are reweighted to 0% and only one category can be scored, the clinician will receive a final score equal to the performance threshold and avoid a penalty.
The AMA has urged CMS to protect physicians from unfair penalties, stating:
“We greatly appreciate CMS for recognizing that physicians and their patients continue to face hardships due to the nationwide shortage of IV fluids. The AMA urges all Federation members to share this information with their members as soon as possible.”
CMS has also extended the MIPS data submission deadline for the 2024 performance year to April 14, 2025. However, the opt-in elections and Partial QP participation deadline remains March 31, 2025.
To apply:
- Sign in to the QPP website: https://qpp.cms.gov
- Select ‘Exceptions Applications’ → ‘Add New Exception’
- Choose ‘Extreme and Uncontrollable Circumstances Exception’
- Select “National IV Fluid Shortage” as the event type
- Provide a brief description of how your practice was impacted
Helpful Links:
- MIPS EUC Exception Application (CMS Announcement)
- 2024 MIPS Opt-In and Voluntary Reporting Election Guide (PDF)
- 2024 Traditional MIPS Data Submission User Guide (PDF)
- More QPP Submission Resources
Physicians are strongly encouraged to act promptly to avoid penalties. The AMA will continue advocating to ensure fair treatment for practices managing care under extraordinary supply constraints.
