CROSSWALK Appendix H: 2025 MIPS Promoting Interoperability Hardship Exception Application Guide

OMB Control Number: 0987-1314
Expiration Date: 02/28/2027

MIPS Promoting Interoperability Performance Category Hardship
Exception Application Guide
2024 Final Document versus 2025 Final Document
Burden impact: The changes in this guide don’t reflect policies in the CY 2026 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:
2024 – Page 1
2025 – Page 1
Reason for Change:
Alignment with current program year.
2024 Final Document text:
Title: 2024 MIPS Promoting Interoperability Performance Category Hardship Exception
Application Guide
2025 Final Document text:
Title: 2025 MIPS Promoting Interoperability Performance Category Hardship Exception
Application Guide

Change #2:
Location:
2025 – Page 6
Reason for Change:
New addition regarding where Medicare Shared Savings Program ACOs can submit
Promoting Interoperability Performance Category Hardship Exception applications.
2025 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Application Overview
Content: Where
• Representatives of Medicare Shared Savings Program ACOs with a QPP
Security Official or QPP Staff User role in the ACO Management System (ACOMS) can access the QPP website using their ACO-MS Username and Password.

Change #3:
Location:
2024 – Page 6
2025 – Page 6
Reason for Change:
Updated dates for new performance year.
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OMB Control Number: 0987-1314
Expiration Date: 02/28/2027

2024 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 December 31, 2024.
2025 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Application Overview
Content: When
• The MIPS Promoting Interoperability Hardship Exception application will close at
8 p.m. ET on December 31, 2025.

Change #4:
Location:
2024 – Page 9
2025 – Page 9
Reason for Change:
Updated title of linked document to align with current performance year.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: See our 2024 MIPS Data Validation Criteria (ZIP, 2MB) for details on the data
validation process.
2025 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: See the 2025 MIPS Data Validation Criteria (ZIP, 2MB) for details on the data
validation process.

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OMB Control Number: 0987-1314
Expiration Date: 02/28/2027

Change #5:
Location:
2025 – Page 12
Reason for Change:
Updated to account for new policy related to the Medicare Shared Savings Program.
2025 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: Medicare Shared Savings Program.
Unless excluded, for performance years beginning on or after January 1, 2025, an ACO
participant, ACO provider/supplier, and ACO professional that is a MIPS eligible
clinician, Qualifying APM Participant (QP), or Partial Qualifying APM Participant (Partial
QP) must:
• Report the MIPS Promoting Interoperability performance category measures and
requirements to MIPS at the individual, group, virtual group, or APM Entity level (i.e.,
ACO reports on behalf of its clinicians); and
• Earn a performance category score for the MIPS Promoting Interoperability performance
category at the individual, group, virtual group, or APM Entity level.
This requirement applies regardless of the Shared Savings Program track in which the
ACO participant, ACO provider/supplier, or ACO professional participates. For more
information, please refer to the Frequently Asked Questions on the Shared Savings
Program Requirement to Report Objectives and Measures for the MIPS Promoting
Interoperability Performance Category.
These ACO participants, ACO providers/suppliers, and ACO professionals can
apply for hardship exceptions and qualify for automatic reweighting just like other
MIPS eligible clinicians.
NOTE: APM Entities, including ACOs, can’t submit an application at the APM Entity
level. You can complete the MIPS Promoting Interoperability Hardship Exception
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 performance category score for the APM Entity.

Change #6
Location:
2025 – Page 13
Reason for Change:
Updated to account for new policy related to the Medicare Shared Savings Program.
2025 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: Medicare Shared Savings Program (continued)
An ACO participant, ACO provider/supplier, or ACO professional is excluded from the
Shared Savings Program’s requirement to report the MIPS Promoting Interoperability
performance category if they meet applicable requirements for an eligible clinician to be
excluded or exempt from reporting the MIPS Promoting Interoperability performance

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OMB Control Number: 0987-1314
Expiration Date: 02/28/2027

•
•
•

category as set forth in the regulations at 42 CFR part 414, subpart O. Applicable
exclusions include:
Not exceeding the low volume threshold as set forth in 42 CFR 414.1310(b)(1)(iii).
An eligible clinician (as defined in 42 CFR 414.1305) who is not a MIPS eligible clinician
as set forth in 42 CFR 414.1310(b)(2).
Reweighting of the MIPS Promoting Interoperability performance category in accordance
with 42 CFR 414.1380(c)(2)(i)(C) granted by CMS based on a significant hardship or
other type of exception for a specific performance year. Bases for reweighting include
being, as defined in 42 CFR 414.1305:
o A non-patient facing clinician;
o A hospital-based clinician;
o An Ambulatory Surgery Center (ASC)-based clinician; or
o In a small practice.
An ACO participant, ACO provider/supplier, or ACO professional cannot be excluded
from the Shared Savings Program’s requirement to report the MIPS Promoting
Interoperability performance category solely on the basis of being a QP or Partial QP. If
a QP or Partial QP meets an exclusion noted above, or is not an eligible clinician, the
QP or Partial QP would not be required to report.
NOTE: An ACO participant, ACO provider/supplier, or ACO professional that meets any
of these exclusions DOES NOT need to submit a MIPS Promoting Interoperability
Hardship Exception application. ACOs, including their ACO participants, ACO
providers/suppliers, and ACO professionals that are MIPS eligible clinicians, QPs, or
Partial QPs should know their status before submitting a hardship exception application,
which cannot be granted because they are already excluded from reporting the MIPS
Promoting Interoperability performance category.

Change #7:
Location:
2024 – Page 16
2025 – Page 18
Reason for Change:
Updated dates for new performance year.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: Step 2: Navigate to Your Exception Applications
• You can create and submit a new exception request until 8 p.m. ET on
December 31, 2024.
2025 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: Step 2: Navigate to Exceptions Application
• You can create and submit a new exception request until 8 p.m. ET on
December 31, 2025.

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OMB Control Number: 0987-1314
Expiration Date: 02/28/2027

Change #8:
Location:
2024 – Page 22
2025 – Page 24
Reason for Change:
Updated title of linked document to align with current performance year.
2024 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: See our 2024 MIPS Data Validation Criteria (ZIP, 2MB) for details on the data
validation process.
2025 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: See the 2025 MIPS Data Validation Criteria (ZIP, 2MB) for details on the data
validation process.

Change #9:
Location:
2024 – Page 34
2025 – Page 36
Reason for Change:
Updated information to align with program changes.
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;
• Ambulatory Surgical Center (ASC)-based;
• Hospital-based; or
• Non-patient facing
2025 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

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OMB Control Number: 0987-1314
Expiration Date: 02/28/2027

Change #10:
Location:
2024 – Page 35
2025 – Page 37
Reason for Change:
Updated performance year references to align with current performance 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.
2025 Final Document text:
Section: Appendices
Content: Appendix B. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS and MVPs Finalized for the 2025 Performance Year: Individual
Clinicians, Groups, and Virtual Groups
The table below illustrates the 2025 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 2027 payment
year.

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OMB Control Number : 0938-1314
Expiration Date: 02/28/2027

Change #11:
Location:
2024 – Page 36 (repeated on page 37)
2025 – Page 38 (repeated on page 39)
Reason for Change:
Updated title and performance year references to align with current performance year.
2024 Final Document text:
Section: Appendices
Content: IPS Performance Category Weight Redistribution Policies Under Traditional
MIPS and MVPs Finalized for the 2024 Performance Year: Individual Clinicians, Groups
and Virtual Groups (Continued)
2025 Final Document text:
Section: Appendices
Content: MIPS Performance Category Weight Redistribution Policies Under Traditional
MIPS and MVPs Finalized for the 2025 Performance Year: Individual Clinicians, Groups
and Virtual Groups (Continued)

Change #12:
Location:
2024 – Page 38
2025 – Page 40
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 2024 Performance Year: Small Practices
The table below illustrates the 2024 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 2025 Performance Year: Small Practices
The table below illustrates the 2025 performance category weights and reweighting
policies that CMS will apply to small practices.

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Change #13:
Location:
2024 – Page 39
2025 – Page 41
Reason for Change:
Updated title performance year reference to align with current performance year.
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 Practice
2025 Final Document text:
Section: Appendices
Content: Appendix C. MIPS Performance Category Weight Redistribution Policies
Under Traditional MIPS Finalized for the 2025 Performance Year: Small Practices
Change #14:
Location:
2023 – Page 40
2024 – Page 42
Reason for Change:
Updated title performance year reference to align with current 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
2025 Final Document text:
Section: Appendices
Content: Appendix D. MIPS Performance Category Weight Redistribution Policies for
APM Entities and the APP Finalized for the 2025 Performance Year

According to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.), no persons are required to respond
to a collection of information unless it displays a valid OMB control number. The valid OMB control number for
this information collection is 0938-1314 (Expiration date: 2/28/2027). This information collection is the tool to
request that MIPS Promoting Interoperability Hardship Exception applications allow you to request that your MIPS
Promoting Interoperability performance category be reweighted to 0%. The time required to complete this
information collection is estimated to average 0.25 hours per response, including the time to review instructions,
search existing data resources, gather the data needed, to review and complete the information collection. This
information collection is voluntary and all information collected will be kept private in accordance with regulations
at 45 CFR 155.260, Privacy and Security of Personally Identifiable Information. Pursuant to this regulation, CMS
may only use or disclose personally identifiable information to the extent that such information is necessary to
carry out their statutory and regulatory mandated functions. If you have comments concerning the accuracy of the
time estimate(s) or suggestions for improving this form, please write to: CMS, 7500 Security Boulevard, Attn: PRA
Reports Clearance Officer, Mail Stop C4-26-05, Baltimore, MD 21244-1850. If you have questions or concerns
regarding where to submit your documents, please contact QPP at qpp@cms.hhs.gov.
Under the Privacy Act of 1974 (5 U.S.C. 552a) any personally identifying information obtained will be kept private
to the extent of the law.

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