Crosswalk: Appendix C1

All-Payer Clinician Initiated Submission Form
CY 2023 Final versus CY 2024 Final
Burden impact: The changes to this form reflect proposals in the CY 2024 Physician Fee
Schedule (PFS) Final Rule for the Quality Payment Program. There are no impacts to burden
as a result of these changes.
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Change #1:
Location: Page 1, Line 39
Reason for Change:
Alignment with current year.
CY 2023 Final Rule text:
2023
CY 2024 Final Rule text:
2024
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Change #2:
Location: Page 1, Line 42
Reason for Change:
Alignment with current year.
CY 2023 Final Rule text:
December 1, 2023 for the 2023
CY 2024 Final Rule text:
December 1, 2024 for the 2024
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Change #3:
Location: Page 2, Line 9
Reason for Change:
Alignment with current year.
CY 2023 Final Rule text:
2022 for the 2023
CY 2024 Final Rule text:
2023 for the 2024
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Change #4:
Location: Page 9, Line 23
Reason for Change:
Regulations amended for 2024
CY 2023 Final Rule text:

1. Does the payment arrangement require at least 75 percent of participating eligible
clinicians in each APM Entity (or each hospital if hospitals are the APM participants) to
use CEHRT as defined in 42 CFR 414.1305 to document and communicate clinical care,
as required by 42 CFR 414.1420(b)? For purposes of this Form, the APM Entity is the
practitioner or group of practitioners that participates in the payment arrangement. [Y/N]

CY 2024 Final Rule text:

1. Does the payment arrangement require APM participants to use CEHRT as defined in 42
CFR 414.1305 to document and communicate clinical care, as required by 42 CFR
414.1420(b)? [Y/N]
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Change #5:
Location: Page 13, Line 26
Reason for Change:
Regulations amended for 2024
CY 2023 Final Rule text:

2. Does the payment arrangement require at least 75 percent of participating eligible
clinicians in each APM Entity (or each hospital if hospitals are the APM participants) to
use CEHRT as defined in 42 CFR 414.1305 to document and communicate clinical care,
as required by 42 CFR 414.1420(b)? [Y/N]
CY 2024 Final Rule text:

2. Does the payment arrangement require APM participants to use CEHRT as defined in 42
CFR 414.1305 to document and communicate clinical care, as required by 42 CFR
414.1420(b)? [Y/N]