Crosswalk: Appendix I1

Extreme and Uncontrollable Circumstances Hardship Exception
Application Guide
2022 Final Document versus 2023 Final Document

Burden impact: The changes in this guide don’t reflect policies in the CY 2024 Physician Fee
Scheduled (PFS) final 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:
2022 – Page 1
2023 – Page 1
Reason for Change:
Alignment with current program year
2022 Final Document text:
Title: 2022 Extreme and Uncontrollable Circumstances Exception Application Guide
2023 Final Document text:
Title: 2023 Extreme and Uncontrollable Circumstances Exception Application Guide

Change #2:
Location:
2022 – Page 2
2023 – Page 2
Reason for Change:
Streamlined section names in table of contents.
2022 Final Document text:
Section: Table of Contents
Content:
How to Use This Guide
Extreme and Uncontrollable Circumstances Exception Application Overview
Extreme and Uncontrollable Circumstances Exception Application Process: Frequently
Asked Questions
Extreme and Uncontrollable Circumstances Exception Application Process: Application
Steps
Help, Resources, Glossary and Version History
Appendices
2023 Final Document text:
Section: Table of Contents
Content:
How to Use This Guide
Overview

Frequently Asked Questions
Application Steps
Help and Version History
Appendices
Change #3:
Location:
2022 – Page 4
2023 – Page 2
Reason for Change:
Moved location of document purpose to table of contents page, no change to purpose.
2022 Final Document text:
Section: How to Use This Guide
Content: Purpose: This guide will provide general information about the Extreme and
Uncontrollable Circumstances (EUC) Exception application and provide step-by-step
instructions on how to complete the application.
2023 Final Document text:
Section: Table of Contents
Content: Purpose: This guide will provide general information about the Extreme and
Uncontrollable Circumstances (EUC) Exception application and provide step-by-step
instructions on how to complete the application.
Change #4:
Location:
2022 – Page 5
2023 – Page 5
Reason for Change:
Added MIPS to section title.
2022 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Overview
Content: Extreme and Uncontrollable Circumstances Exception Application Overview
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Change #5:
Location:
2022 – Page 6
2023 – Page 6

Reason for Change:
Updated dates for new performance year.
2022 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Overview
Content:
When UPDATE: The EUC Exception application to allow individuals, groups, virtual
groups, and APM Entities the opportunity to request performance category reweighting
due to the COVID-19 PHE deadline has been extended until 8 p.m. ET on March 3,
2023.
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content:
When The MIPS EUC Exception application will close at 8 p.m. ET on January 2, 2024.

Change #6:
Location:
2022 – Page 7
2023 – Page 7
Reason for Change:
Updated dates for new year
2022 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Overview
Content:
If you submit Medicare Part B Claims measures during the performance year, this will
override quality performance category reweighting. However, if you request and are
approved for reweighting in all 4 performance categories and don’t submit data for
another performance category, your MIPS final score for the 2022 MIPS performance
period would be equal to the performance threshold and you would receive a neutral
payment adjustment in 2024.
When fewer than 2 performance categories can be scored (meaning 1 performance
category is weighted at 100% of your MIPS final score, and the other performance
categories are weighted at 0%), the MIPS final score for the 2022 MIPS performance
period would be equal to the performance threshold and you would receive a neutral
payment adjustment in 2024.
You will be scored in any performance category that’s not included in your application,
unless you qualify for reweighting through another policy.
For example:
• If you don’t meet the case minimum for any cost measures, the cost performance
category will be reweighted.
• You qualify for reweighting under the automatic Extreme and Controllable
Circumstances policy.

Review the 2022 Automatic Extreme and Uncontrollable Circumstances
Fact Sheet (PDF) for additional information.
• Certain clinician types and individuals, groups, and virtual groups with certain
special statuses qualify for automatic reweighting of the Promoting
Interoperability performance category.
o For additional information on automatic reweighting on Promoting
Interoperability, review the 2022 Promoting Interoperability Quick Start
Guide (PDF).
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content:
If you submit Medicare Part B Claims measures during the performance year, this will
override quality performance category reweighting. However, if you request and are
approved for reweighting in all 4 performance categories and don’t submit data for
another performance category, your MIPS final score for the 2023 MIPS performance
period would be equal to the performance threshold and you would receive a neutral
payment adjustment in 2025.
When fewer than 2 performance categories can be scored (meaning 1 performance
category is weighted at 100% of your MIPS final score, and the other performance
categories are weighted at 0%), the MIPS final score for the 2023 MIPS performance
period would be equal to the performance threshold and you would receive a neutral
payment adjustment in 2025.
You will be scored in any performance category that’s not included in your application,
unless you qualify for reweighting through another policy.
For example:
• If you don’t meet the case minimum for any cost measures, the cost performance
category will be reweighted.
• You qualify for reweighting under the automatic Extreme and Controllable
Circumstances policy.
o Review the 2023 Automatic Extreme and Uncontrollable Circumstances
Fact Sheet (PDF) for additional information.
• Certain clinician types and individuals, groups, and virtual groups with certain
special statuses qualify for automatic reweighting of the Promoting
Interoperability performance category.
o For additional information on automatic reweighting on Promoting
Interoperability, review the 2023 Promoting Interoperability Quick Start
Guide (PDF).
o

Change #7:
Location:
2022 – N/A
2023 – Page 11
Reason for Change:

Updated based on policy changes for the 2023 performance year.
2022 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Overview
Content: N/A
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content:
Policies for Subgroups Reporting an MVP
Clinicians who register to report an MVP as a subgroup will inherit the performance
category reweighting approved for their affiliated group.
• Data submission by the affiliated group won’t override performance category
reweighting for the subgroup.
• Data submission by the subgroup won’t override performance category reweighting
for the affiliated group.
Clinicians who register to report an MVP as a subgroup can request performance
category reweighting at the subgroup level by contacting the QPP Service Center.
• Subgroups won’t be able to submit a MIPS EUC Exception application as outlined in
this guide.
A subgroup’s request for reweighting will be superseded by any reweighting
approved for their affiliated group.

Change #8:
Location:
2022 – Page 8
2023 – Page 8
Reason for Change:
Updated list of models for new program year.
2022 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Overview
Content:
APM Entities in the following models can submit an EUC application on behalf of their
MIPS eligible clinicians:
• Medicare Shared Saving Program
• Vermont Medicare ACO Model
• Bundled Payments for Care Improvement (BPCI) Advanced Model
• Oncology Care Model (OCM)
• Maryland Total Cost of Care
• Independence at Home Demonstration
• Primary Care First (PCF)
• Value in Opioid Use Disorder Treatment (ViT)
• Direct Contracting (DC)
• Comprehensive Care for Joint Replacement (CJR) Payment
• Kidney Care Choices (KCC)

2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content:
APM Entities in the following models can submit an EUC Exception application on behalf
of their MIPS eligible clinicians:
• Medicare Shared Saving Program
• Vermont Medicare ACO Model
• Bundled Payments for Care Improvement (BPCI) Advanced Model
• Enhanced Oncology Model (EOM)
• Maryland Total Cost of Care
• Independence at Home Demonstration
• Primary Care First (PCF)
• Value in Opioid Use Disorder Treatment (ViT)
• ACO Realizing Equity Access and Community Health (REACH) Model
• Comprehensive Care for Joint Replacement (CJR) Payment
• Kidney Care Choices (KCC)
Change #9
Location:
2022 – Page 15
2023 – Page 16
Reason for Change:
Updated for new performance year.
2022 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Process:
Frequently Asked Questions
Content:
Are We Required to Submit Documentation with Our EUC Exception Application?
• No, you aren’t required to submit documentation with your application.
• However, you should retain documentation of the circumstances supporting your
application for your own records in the event that you are selected by CMS for data
validation or an audit. See our 2022 MIPS Data Validation Criteria Guide (ZIP) for
information on the data validation and audit process.
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Frequently Asked Questions
Content:
Are We Required to Submit Documentation with Our EUC Exception Application?
• No, you aren’t required to submit documentation with your application.
• However, you should retain documentation of the circumstances supporting your
application for your own records in the event that you are selected by CMS for data
validation or an audit. See our 2023 MIPS Data Validation Criteria Guide (ZIP) for
information on the data validation and audit process.

Change #10:
Location:
2022 – N/A
2023 – Page 17
Reason for Change:
Added new questions based on service center inquiry analysis.
2022 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Process:
Frequently Asked Questions
Content: N/A
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Frequently Asked Questions
Content:
Can we submit one MIPS EUC Exception application at the group level rather than
separate applications for each individually eligible clinician?
• Yes, you can submit a group-level application instead of separate applications for
each clinician if the EUC applies to the whole group. However, if the circumstances
are specific to a subset of clinicians in the group, you’d need to submit individual
applications for each of those clinicians.
Our third party intermediary experienced issues and is unable to submit data on
our behalf. Can we submit an EUC Exception application for this issue?
• As noted in the Calendar Year 2018 Quality Payment Program Final Rule, extreme
and uncontrollable circumstances, such as natural disasters, may affect a clinician's
ability to access or submit quality measures via all submission mechanisms
(effectively rendering the measures unavailable to the clinician), as well as the
availability of numerous improvement activities. In addition, damage to a facility
where care is provided due to a natural disaster, such as a hurricane, could result in
practice management and clinical systems that are used for the collection or
submission of data to be down, thus impacting a clinician's ability to submit
necessary information via Qualified Registry, QCDR, CMS Web Interface, or claims.
• This policy doesn’t include issues that third party intermediaries, such as Electronic
Health Record vendors (EHRs), QCDRs, or Qualified Registries, might have
submitting information to MIPS on behalf of a MIPS eligible clinician.
• Instead, this policy is geared towards events, such as natural disasters, that affect
the MIPS eligible clinician's ability to submit data to the third party intermediary,
which in turn, could affect the ability of the clinician (or the third party intermediary
acting on their behalf) to successfully submit measures and activities to MIPS.

Change #11:
Location:
2022 – Page 18

2023 – N/A
Reason for Change:
Deadline extension was specific to the 2022 performance year.
2022 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Process:
Application Steps
Content: We’ve extended the 2022 MIPS EUC Exception application to allow
individuals, groups, virtual groups, and APM Entities to submit an application requesting
MIPS performance category reweighting due to the ongoing COVID-19 PHE. 2022 MIPS
EUC Exception applications citing COVID-19 as the triggering event can be submitted
until 8 p.m. ET on Friday, March 3, 2023.
2023 Final Document text:
Section: N/A
Content: N/A

Change #12:
Location:
2022 – N/A
2023 – Page 22
Reason for Change:
Updated to align with current policy.
2022 Final Document text:
Section: N/A
Content: N/A
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Application Steps
Content: Note: If reporting an MVP with a subgroup, you must contact the QPP Service
Center to request an Extreme and Uncontrollable Circumstances Exception application.
Change #13:
Location:
2022 – Page 25
2023 – Page 27
Reason for Change:
Updated for new performance year.
2022 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Process:
Application Steps
Content: Provide a brief description about the data collection challenges that you
experienced due to the extreme and uncontrollable event and how your 2022
performance data will be impacted.

2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Application Steps
Content: Provide a brief description about the data collection challenges that you
experienced due to the extreme and uncontrollable event and how your 2023
performance data will be impacted.

Change #14:
Location:
2022 – Page 25
2023 – Page 27
Reason for Change:
Updated for new performance year.
2022 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Process:
Application Steps
Content:
See our 2022 MIPS Data Validation Criteria for information on the data validation and
audit process.
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Application Steps
Content:
See our 2023 MIPS Data Validation Criteria for information on the data validation and
audit process.
Change #15:
Location:
2022 – 27
2023 – Page 29
Reason for Change:
Updated screenshot disclaimer to replace the URL with “QPP website” in alignment with
current style guide preferences.
2022 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Application Steps
Content: Once you are done with your application, review the disclosures, then select
the Submit for Review button.
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Application Steps

Content: Once you’re done with your application, review the disclosures, then select the
Certify & Submit button.
Change #16:
Location:
2022 – Page 29
2023 – Page 31
Reason for Change:
Updated section break title in alignment with changes to table of contents.
2022 Final Document text:
Section: Help, Resources, Glossary, and Version History
Content: Help, Resources, Glossary, and Version History
2023 Final Document text:
Section: Help and Version History
Content: Help and Version History

Change #19:
Location:
2022 – Page 30
2023 – Page 32
Reason for Change:
Updated service center contact information to account for a new contact option and
revisions to standardized language.
2022 Final Document text:
Section: Help, Resources, Glossary, and Version History
Content: Contact the Quality Payment Program at 1-866-288-8292, Monday through
Friday, 8 a.m.-8 p.m. ET or by e-mail at: QPP@cms.hhs.gov.
• Customers who are hearing impaired can dial 711 to be connected to a TRS
Communications Assistant
2023 Final Document text:
Section: Help and Version History
Content: Contact the Quality Payment Program Service Center by email at
QPP@cms.hhs.gov, create a QPP Service Center ticket, or by phone at 1-866-288-8292
(Monday through Friday, 8 a.m. - 8 p.m. ET).
• Customers who are hearing impaired can dial 711 to be connected to a TRS
Communications Assistant

Change #20:
Location:
2022 – Page 31
2023 – N/A

Reason for Change:
Additional resources section deemed superfluous as links to these resources are
included earlier in the document. (Standardized change across all resources.)
2022 Final Document text:
Section: Help, Resources, Glossary, and Version History
Content: The Quality Payment Program Resource Library houses fact sheets, measure
specifications, specialty guides, technical guides, user guides, helpful videos, and more.
We will update this table as more resources become available.
• 2022 Automatic Extreme and Uncontrollable Circumstances Policy Fact Sheet (PDF)
• 2022 MIPS Promoting Interoperability Hardship Exception Application Guide (PDF)
2023 Final Document text: N/A

Change #21:
Location:
2022 – Page 34
2023 – Page 35
Reason for Change:
Updated for new performance year.
2022 Final Document text:
Section: Appendices
Content: Appendix A1: 2022 Performance Year MIPS Performance Category Weight
Redistribution Policies for Individual Clinicians, Groups, Virtual Groups, and APM
Entities Reporting Traditional MIPS
The table below illustrates the 2022 performance category weights and reweighting
policies that CMS will apply to clinicians, groups, and virtual groups reporting traditional
MIPS.
2023 Final Document text:
Section: Appendices
Content: Appendix A1.
2023 Performance Year MIPS Performance Category Weight Redistribution Policies
for Individual Clinicians, Groups, Virtual Groups, and APM Entities Reporting Traditional
MIPS or MVPs
The table below illustrates the 2023 performance category weights and reweighting
policies that CMS will apply to clinicians, groups, and virtual groups reporting traditional
MIPS or MVPs.

Change #22:
Location:
2022 – Page 36
2023 – Page 37
Reason for Change:
Updated for new performance year.

2022 Final Document text:
Section: Appendices
Content: Appendix A2. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS Finalized for the 2022 Performance Year: Small Practices
The table below illustrates the 2022 performance category weights and reweighting
policies that CMS will apply to small practices.
2023 Final Document text:
Section: Appendices
Content: Appendix A2. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS Finalized for the 2023 Performance Year: Small Practices
The table below illustrates the 2023 performance category weights and reweighting
policies that CMS will apply to small practices.

Change #23:
Location:
2022 – Page 38
2023 – Page 39
Reason for Change:
Updated for new performance year.
2022 Final Document text:
Section: Appendices
Content: Appendix B. 2022 Performance Year MIPS Performance Category Weight
Redistribution Policies for APM Entities and APM Participants Reporting the APP
The table below illustrates the 2022 performance category weights and reweighting
policies that CMS will apply to APM Entities reporting traditional MIPS and to individual
clinicians, groups and APM Entities reporting via the APP.
2023 Final Document text:
Section: Appendices
Content: Appendix B. 2023 Performance Year MIPS Performance Category Weight
Redistribution Policies for APM Entities and APM Participants Reporting the APP
The table below illustrates the 2023 performance category weights and reweighting
policies that CMS will apply to APM Entities reporting traditional MIPS and to individual
clinicians, groups and APM Entities reporting via the APP.
Change #24:
Location:
2022 – Pages 6, 15, 17 – 28
2023 – Pages 6, 15, 16, 19 – 30
Reason for Change:
Updated language for referring to QPP website.

2022 Final Document text:
Section: throughout the guide
Content: qpp.cms.gov
2023 Final Document text:
Section: throughout the guide
Content: QPP website