Crosswalk - Eligible Clinician Initiated Submission Form

All-Payer Clinician Initiated Submission Form
CY 2020 Final versus CY 2021 Proposed

Burden impact: The changes to this form reflect proposals in the CY2021 Physician Fee
Schedule (PFS) Proposed 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 2020 Final Rule text:
2019
CY 2021 Proposed Rule text:
2020
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Change #2:
Location: Page 1, Line 42
Reason for Change:
Alignment with current year.
CY 2020 Final Rule text:
December 1, 2019 for the 2019
CY 2021 Proposed Rule text:
December 1, 2020 for the 2020
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Change #3:
Location: Page 2, Line 9
Reason for Change:
Alignment with current year.
CY 2020 Final Rule text:
2018 for the 2019
CY 2021 Proposed Rule text:
2019 for the 2020
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Change #4:
Location: Page 3, Line 8
Reason for Change:
Edited for clarity
CY 2020 Final Rule text:
Additional information regarding electronic Form access and submission process will be
available following publication of the 2018 Quality Payment Program Final Rule.
In addition to APM Entities and Eligible Clinicians, we allow those authorized to report on
behalf of APM Entities or Eligible Clinicians to complete this Form.

CY 2021 Proposed Rule text:
We allow those authorized to report on behalf of APM Entities or Eligible Clinicians to
complete this Form.
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Change #5:
Location: Page 9, Line 6
Reason for Change:
Alignment with current year and proposed changes.
CY 2020 Final Rule text:
For performance year 2020, is the total amount that your participating entity potentially
owes or foregoes under the payment arrangement at least 4 percent of the average
estimated total revenue of all the participating providers or other entities under the
payer? [Y/N]
If yes, please describe how the amount that an APM entity owes or foregoes is
calculated. [Text Box]
CY 2021 Proposed Rule text:
For performance year 2021 and later, is the total amount that your participating entity
potentially owes or foregoes under the payment arrangement at least at least 5 percent
of the average estimated total revenue of the participating providers or other entities
under the payer in 2021? [Y/N]
If yes, please describe how the amount that an APM entity owes or foregoes is
calculated. [Text Box]
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Change #6:
Location: Page 9, Line 11
Reason for Change:
Edited for clarity.
CY 2020 Final Rule text:
2
CY 2021 Proposed Rule text:
1
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Change #7:
Location: Page 9, Line 19
Reason for Change:
Edited for clarity.
CY 2020 Final Rule text:
3
CY 2021 Proposed Rule text:
2