Crosswalk - Appendix H2: 2024 MIPS Promoting Interoperability Hardship Exception Application Guide

MIPS Promoting Interoperability Performance Category Hardship
Exception Application Guide
2023 Final Document versus 2024 Final Document
Burden impact: The changes in this guide don’t reflect policies in the CY 2025 Physician Fee
Scheduled (PFS) proposed rule for the Quality Payment Program. There is no impact to burden
as a result of the changes reflected in this crosswalk.
Change #1:
Location:
2023 – Page 1
2024 – Page 1
Reason for Change:
Alignment with current program year.
2023 Final Document text:
Title: 2023 MIPS Promoting Interoperability Performance Category Hardship Exception
Application Guide
2024 Final Document text:
Title: 2024 MIPS Promoting Interoperability Performance Category Hardship Exception
Application Guide
Change #2:
Location:
2023 – Page 6
2024 – Page 6
Reason for Change:
Clarified what entities can submit Promoting Interoperability Performance Category
Hardship Exception applications.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Application Overview
Content: Who
Some clinicians, groups and virtual groups automatically qualify for reweighting of the
Promoting Interoperability performance category.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Application Overview
Content: Who
• APM Entities can’t submit an application at the APM Entity level.

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Change #3:
Location:
2023 – Page 6
2024 – Page 6
Reason for Change:
Updated to account for program changes.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Application Overview
Content: Why
• You have decertified electronic health record (EHR) technology
• You lack control over the availability of certified EHR technology (CEHRT)
o Lacking 2015 Edition CEHRT doesn’t qualify as a reason to submit an
exception application
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Application Overview
Content: Why
• You have decertified electronic health record (EHR) technology (decertified under
the Office of the National Coordinator for Health Information Technology's (ONC)
Health IT Certification Program).
• You lack control over the availability of certified EHR technology (CEHRT).
o Simply lacking CEHRT functionality that meets ONC’s certification criteria
in 45 CFR 170.315 doesn’t qualify as a reason to submit an exception
application.
Change #4:
Location:
2023 – Page 6
2024 – Page 6
Reason for Change:
Updated dates for new performance year.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Application Overview
Content: When
The Promoting Interoperability Hardship Exception application will close at 8 p.m. ET on
January 2, 2024.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Application Overview
Content: When
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The Promoting Interoperability Hardship Exception application will close at 8 p.m. ET on
December 31, 2024.
Change #5:
Location:
2023 – Page 8
2024 – Page 8
Reason for Change:
Clarify group levels allowed to complete a Promoting Interoperability Performance
Hardship application.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: You can still submit data for the MIPS Promoting Interoperability performance
category.
• If your circumstances change and you’re able to collect and submit your
Promoting Interoperability data, we’ll disregard your Hardship Exception
application and you’ll be scored in this performance category.
• You’ll also be scored in this performance category if you attest to any data, such
as selecting performance period dates or responding to attestation statements,
during the submission period.
• Small practices qualify for automatic reweighting of the Promoting Interoperability
performance category.
Reminder: Small practices qualify for automatic reweighting.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: Did You Know? Subgroups can’t submit a Promoting Interoperability Hardship
Exception at the subgroup level but will inherit any reweighting approved for their
affiliated group.
You can still submit data for the MIPS Promoting Interoperability performance category.
• If your circumstances change and you’re able to collect and submit your
Promoting Interoperability data, we’ll disregard your Hardship Exception
application and you’ll be scored in this performance category.
• You’ll also be scored in this performance category if you attest to any data, such
as selecting performance period dates or responding to attestation statements,
during the submission period.
Reminder: Small practices qualify for automatic reweighting of the Promoting
Interoperability performance category.

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Change #6:
Location:
2023 – Page 9
2024 – Page 9
Reason for Change:
Updated title of linked document to align with current performance year.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: You aren’t required to submit documentation with your application.
• However, clinicians, groups, and virtual groups should retain documentation of their
circumstances supporting their application for their own records in the event they’re
selected by CMS for data validation or audit. See our 2023 MIPS Data Validation
Criteria (ZIP) for details on the data validation process.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: You aren’t required to submit documentation with your application.
However, clinicians, groups, and virtual groups should retain documentation of their
circumstances supporting their application for their own records in the
event they’re selected by CMS for data validation or audit. See our 2024 MIPS Data
Validation Criteria (ZIP, 2MB) for details on the data validation process.
Change #7
Location:
2023 – Page 9
2024 – Page 9
Reason for Change:
Updated to account for new policy and program dates.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: You may still be able to report if your EHR product is decertified during the
2023 performance year.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: You may still be able to report if your EHR product is decertified under ONC’s
Health IT Certification Program during the 2024 performance year.

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Change #8:
Location:
2023 – Page 11
2024 – Page 11
Reason for Change:
Clarify group level to complete a Promoting Interoperability Performance Hardship
application.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: If you’re participating in MIPS at the APM Entity level (either reporting
traditional MIPS or the APP), you would complete the application as an individual or
group.
• If approved, the clinician will receive the APM Entity’s score, but will be excluded from
the calculation when we create an average Promoting Interoperability score for the
APM Entity.
APM Entities reporting the APP or traditional MIPS can’t submit a Promoting
Interoperability Hardship Exception application on behalf of the entire Entity.
• When participating in MIPS as an APM Entity, the Promoting Interoperability
performance category is still reported at the individual or group level.
A MIPS Promoting Interoperability performance category hardship
exception doesn’t exempt you from reporting on any CEHRT activities required for
participation in your APM.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: If you’re participating in MIPS at the APM Entity level (either reporting
traditional MIPS or the APP), you can complete the application as an individual or
group.
• If approved, the MIPS eligible clinician will receive the APM Entity’s score, but will be
excluded from the calculation when we create an average Promoting Interoperability
score for the APM Entity.
APM Entities reporting the APP or traditional MIPS can’t submit a Promoting
Interoperability Hardship Exception application on behalf of the entire APM Entity.
• MIPS eligible clinicians in the APM Entity would need to submit the MIPS Promoting
Interoperability Performance Category Hardship Exception application at the individual
or group level, as appropriate to their circumstances.
A MIPS Promoting Interoperability performance category hardship exception doesn’t
exempt you from reporting on any CEHRT activities as may be required by your APM.
Reminder: The Promoting Interoperability Performance Category Hardship Exception
application isn’t available to APM Entities.

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Change #9:
Location:
2023 – Page 16
2024 – Page 16
Reason for Change:
Updated dates for new performance year.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps:
Content: You can create and submit a new exception request until 8 p.m. ET on
January 2, 2024.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: You can create and submit a new exception request until 8 p.m. ET on
December 31, 2024.

Change #10:
Location:
2023 – Page 22
2024 – Page 22
Reason for Change:
Updated title of linked document to align with current performance year.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps:
Content: Note: You don’t need to submit supporting documentation with your
application. However, you should retain documentation of the circumstances supporting
your application for your own records in case you are selected by CMS for data
validation or an audit. See our 2023 MIPS Data Validation Criteria for details on the data
validation process.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps:
Content: Note: You don’t need to submit supporting documentation with your
application. However, you should retain documentation of the circumstances supporting
your application for your own records in case you are selected by CMS for data
validation or an audit. See our 2024 MIPS Data Validation Criteria for details on the data
validation process.

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Change #11:
Location:
2023 – Page 27
2024 – Page 27
Reason for Change:
Updated to account for new policy.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps:
Content: Enter the date that your EHR was decertified and your ONC-ACB Certification
ID. Then, review the attestation statement and select “I attest.”
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps:
Content: Enter the date that your EHR was decertified (under ONC’s Health IT
Certification Program) and your ONC-ACB Certification ID. Then, review the
attestation statement and select “I attest.”
Change #12:
Location:
2023 – Page 34
2024 – Page 34
Reason for Change:
Updated information to align with program changes.
2023 Final Document text:
Section: Appendices
Content: You have one of these Special Statuses:
• Small Practice;
• Ambulatory Surgical Center (ASC)-based;
• Hospital-based; or
• Non-patient facing
You are one of these clinician types:
• Clinical social worker
• Physical therapist
• Occupational therapist
• Qualified speech-language pathologist
• Qualified audiologist
• Clinical psychologist
• Registered dietitian or nutrition professional
2024 Final Document text:
Section: Appendices
Content: You're the following clinician type or have one of these Special Statuses:
• Clinical Social Worker
• Small Practice;
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•
•
•

Ambulatory Surgical Center (ASC)-based;
Hospital-based; or
Non-patient facing

Change #13:
Location:
2023 – Page 35
2024 – Page 35
Reason for Change:
Updated title and performance year references to align with current performance year.
2023 Final Document text:
Section: Appendices
Content: Appendix B. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS Finalized for the 2023 Performance Year: Individual Clinicians,
Groups and Virtual Groups
The table below illustrates the 2023 performance category weights and reweighting
policies that CMS will apply to clinicians, groups, and virtual groups reporting via
traditional MIPS.
Important Reminders:
• Individual Clinicians, Groups, Virtual Groups: If fewer than 2 performance categories
can be scored (meaning 1 performance category is weighted at 100%, or all
performance categories are weighted at 0%), the clinician, group, or virtual group will
receive a final score equal to the performance threshold and the MIPS eligible
clinicians will receive a neutral payment adjustment in the 2025 payment year.
2024 Final Document text:
Section: Appendices
Content: Appendix B. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS and MVPs Finalized for the 2024 Performance Year: Individual
Clinicians, Groups, and Virtual Groups
The table below illustrates the 2024 performance category weights and reweighting
policies that CMS will apply to clinicians, groups, and virtual groups reporting via
traditional MIPS or MVPs.
Important Reminders:
• Individual Clinicians, Groups, Virtual Groups: If fewer than 2 performance categories
can be scored (meaning 1 performance category is weighted at 100%, or all
performance categories are weighted at 0%), the clinician, group, or virtual group will
receive a final score equal to the performance threshold and the MIPS eligible
clinicians will receive a neutral payment adjustment in the 2026 payment year.

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Change #14:
Location:
2023 – Page 36 (repeated on page 37)
2024 – Page 36 (repeated on page 37)
Reason for Change:
Updated title and performance year references to align with current performance year.
2023 Final Document text:
Section: Appendices
Content: MIPS Performance Category Weight Redistribution Policies Under Traditional
MIPS Finalized for the 2023 Performance Year: Individual Clinicians, Groups and Virtual
Groups (Continued)
2024 Final Document text:
Section: Appendices
Content: MIPS Performance Category Weight Redistribution Policies Under Traditional
MIPS and MVPs Finalized for the 2024 Performance Year: Individual Clinicians, Groups
and Virtual Groups (Continued)
Change #15:
Location:
2023 – Page 38
2024 – Page 38
Reason for Change:
Updated title and performance year references to align with current performance year.
2023 Final Document text:
Section: Appendices
Content: Appendix C. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS Finalized for the 2023 Performance Year: Small Practice
The table below illustrates the 2023 performance category weights and reweighting
policies that CMS will apply to small practices.
2024 Final Document text:
Section: Appendices
Content: Appendix C. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS Finalized for the 2024 Performance Year: Small Practices
The table below illustrates the 2024 performance category weights and reweighting
policies that CMS will apply to small practices.

9

Change #16:
Location:
2023 – Page 39
2024 – Page 39
Reason for Change:
Updated title performance year reference to align with current performance year.
2023 Final Document text:
Section: Appendices
Content: Appendix C. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS Finalized for the 2023 Performance Year: Small Practice
2024 Final Document text:
Section: Appendices
Content: Appendix C. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS Finalized for the 2024 Performance Year: Small Practices
Change #17:
Location:
2023 – Page 39 (repeated on page 40)
2024 – Page 39 (repeated on page 40)
Reason for Change:
Added clarifying language on payment adjustments.
2023 Final Document text:
Section: Appendices
Content: Note: If you have multiple performance categories reweighted to 0% so that a
single performance category is weighted at 100% of your final score, you’ll receive a
score equal to the performance threshold regardless of any data submitted or not
submitted. See next slide for additional information.
2024 Final Document text:
Section: Appendices
Content: Note: If you have multiple performance categories reweighted to 0% so that a
single performance category is weighted at 100% of your final score, you’ll receive a
score equal to the performance threshold regardless of any data submitted and you’ll
receive a neutral payment adjustment.

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Change #18:
Location:
2023 – Page 40
2024 – Page 40
Reason for Change:
Updated performance year references and clarified performance category weight for
APP.
2023 Final Document text:
Section: Appendices
Content: Appendix D. MIPS Performance Category Weight Redistribution Policies for
APM Entities and the APP Finalized for the 2023 Performance Year
The table below illustrates the 2023 performance category weights and reweighting
policies that apply to individual clinicians, groups and APM Entities reporting the APP.
Reminders:
• Cost is not scored under the APP.
• There are no reporting requirements for the improvement activities performance
category under the APP for the 2023 performance year. Participants reporting via the
APP will automatically receive full credit for the improvement activities performance
category for the 2023 performance year.
2024 Final Document text:
Section: Appendices
Content: Appendix D. MIPS Performance Category Weight Redistribution Policies for
APM Entities and the APP Finalized for the 2024 Performance Year
The table below illustrates the 2024 performance category weights and reweighting
policies that apply to individual clinicians, groups, and APM Entities reporting via the APP.
Reminders:
• The cost performance category weight is zero percent for clinicians scored through
the APP.
• There are no reporting requirements for the improvement activities performance
category under the APP for the 2024 performance year. Participants reporting via the
APP will automatically receive full credit for the improvement activities performance
category for the 2024 performance year.

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