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Policy Snapshot

March 22, 2024

In response to the Change Healthcare cyberattack in late February, the Centers for Medicare & Medicaid Services (CMS) extended the data submission deadline and is now reopening the 2023 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances (EUC) Exception Application to provide relief to MIPS-eligible clinicians impacted by this cybersecurity incident. The application will be open for the remainder of the extended data submission period, which closes April 15, 2024, at 8:00 PM ET.

IMPORTANT: Because CMS is reopening the 2023 MIPS EUC Exception Application window in response to the Change Healthcare cyberattack, CMS will only approve applications citing this cyberattack as the basis for requesting reweighting under the MIPS EUC Exception. Any applications submitted for reasons outside of the Change Healthcare cyberattack will be denied. Additionally, any data submitted to CMS will override your application for those performance categories.

How Do I Apply?

  • Sign in to the QPP website.
  • Select ‘Exceptions Applications’ on the left-hand navigation.
  • Select ‘Add New Exception.’
  • Select ‘Extreme and Uncontrollable Circumstances Exception.’
  • Complete the application. You MUST select “Ransom/Malware” as the Event Type and include “Change Healthcare cyberattack” in the Event Description.
  • Reminder: Any applications submitted for reasons outside of the Change Healthcare cyberattack will be denied.

Applications are reviewed and processed on a rolling basis.

Don’t wait for the April 15 deadline if the Change Healthcare cyberattack is currently preventing you from submitting data, or if you anticipate that it might.

If your application is approved, you can still submit data should circumstances change before the submission deadline.

Additional Resources

For more information on the MIPS EUC Exception Application:

Review the 2023 MIPS Extreme and Uncontrollable Circumstances Exception Application Guide.

For more information on the Change Healthcare Cyberattack: