No More COVID and Cyberattack EUC Exemptions – Why MIPS Compliance Matters in 2025

Your Medicare Reimbursement and Reputation Are on the Line

For the past few years, outpatient practices participating in the Merit-based Incentive Payment System (MIPS) have had the option to claim hardship exemptions due to COVID-19 and, more recently, the Change Healthcare cyberattack. These temporary relief programs protected practices from penalties, allowing them to bypass reporting requirements without financial consequences.

That era is over.

As of 2025, these hardship exemptions are no longer valid. If you’ve relied on them in the past, it’s critical to act now to ensure your practice meets MIPS requirements. Failure to comply could lead to devastating financial and reputational consequences.

What’s at Stake?

Choosing not to participate in MIPS isn’t just an internal decision—it has real-world financial and reputational impacts that can put your practice at a competitive disadvantage.

🔻 Reimbursement Penalty: A staggering -9% reduction in Medicare reimbursements for failing to participate. A penalty of this size could amount to tens of thousands of dollars lost for many outpatient practices.

🔎 Public Score Transparency: Your MIPS score is public information. A score of zero is visible to payers, competitors, and patients on CMS’s Care Compare website. This could affect patient trust, referrals, and payer negotiations.

📉 Competitive Disadvantage: High-performing practices will have strong, publicly visible MIPS scores, setting them apart from those that do not participate. Patients and payers look at these scores when making decisions about where to seek care and who to contract with.

🚨 CMS is Paying Attention: In 2025, CMS has enhanced its auditing and compliance oversight to ensure MIPS participants are actively reporting and meeting data completeness requirements. Simply assuming that non-reporting won’t be noticed is a risky gamble.

Act Now – MIPS Quality Has a 360-Day Reporting Period

Unlike other programs with short reporting windows, MIPS Quality reporting requires a full 360 days of data. This means:
If you’re not tracking and submitting data now, you may already be behind.
Waiting too long will make meeting minimum data completeness thresholds impossible.
Improvement Activities (90-days) and Promoting Interoperability (180-days) require proactive planning, documentation, and validation.

Many practices underestimate the time it takes to collect, validate, and submit MIPS data—waiting until later in the year often results in rushed, incomplete, or incorrect reporting, leading to penalties.

👉 The sooner you act, the better your outcomes.

Get Expert Help from Chirpy Bird

At Chirpy Bird Inc., we specialize in helping outpatient practices navigate MIPS participation, ensuring they meet Quality, Promoting Interoperability, and Improvement Activities requirements without stress or confusion.

🔹 Customized MIPS strategy based on your practice’s size, specialty, and reporting history
🔹 Hands-on guidance for tracking, submitting, and optimizing MIPS measures
🔹 Ongoing support to ensure compliance and maximize your score

📞 Don’t wait! Contact us today to develop a strategy for 2025 MIPS success.

📅 Schedule a Consultation Now

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Understanding MIPS Performance Categories for 2025