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Centers for Medicare & Medicaid Services Quality Payment Program
Merit-based Incentive Payment System (MIPS) Automatic Extreme and Uncontrollable Circumstances (EUC) Policy Applied to MIPS Eligible Clinicians Following California Wildfires for 2024 and 2025 Participation

In response to the California wildfires, as identified by both the Health and Human Services (HHS) Public Health Emergency (PHE) declaration (California [ https://aspr.hhs.gov/legal/PHE/Pages/CA-Wildfires-Jan2025.aspx ]) and Federal Emergency Management Agency (FEMA) disaster declaration (DR-4856-CA [ https://www.fema.gov/disaster/4856/designated-areas ]), the Centers for Medicare & Medicaid Services (CMS) has determined that the MIPS automatic EUC policy will apply to MIPS eligible clinicians in designated affected counties of California for both the 2024 and 2025 performance periods.

MIPS eligible clinicians in these areas will be automatically identified and have all 4 performance categories reweighted to 0% during the data submission period for the 2024 performance period (January 2 to March 31, 2025) and 2025 performance period (January 2 to March 31, 2026). This will result in a score equal to the performance threshold, and they'll receive a neutral payment adjustment for the 2026 and 2027 MIPS payment years. 

However, if MIPS eligible clinicians in these areas submit data on 2 or more performance categories for either/both performance years, they’ll be scored on those performance categories and receive a payment adjustment based on their MIPS final score(s). 

NOTE: The MIPS automatic EUC policy doesn’t apply to MIPS eligible clinicians participating in MIPS as a group, subgroup, virtual group, or Alternative Payment Model (APM) Entity. However, groups, virtual groups, and APM Entities can request reweighting through the EUC Exception application. Subgroups will inherit any reweighting approved for their affiliated group; they can’t request reweighting independent of their affiliated group’s status. 

*For More Information  *

Please reference the MIPS EUC Exception section on the Quality Payment Program Exception Applications webpage and 2024 MIPS Automatic EUC Policy Fact Sheet (PDF, 401KB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2840/2024-MIPS-Automatic-EUC-Policy.pdf ] and 2025 MIPS Automatic EUC Policy Fact Sheet (PDF, 326KB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/3164/2025-MIPS-Automatic-EUC-Policy.pdf ].

Quality Payment Program [ https://qpp.cms.gov/resources/help-and-support ]


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