Crosswalk - Appendix I2: 2024 MIPS Extreme and Uncontrollable Circumstances Exception Application Guide

Extreme and Uncontrollable Circumstances 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 Extreme and Uncontrollable Circumstances Exception Application Guide
2024 Final Document text:
Title: 2024 Extreme and Uncontrollable Circumstances Exception Application Guide
Change #2:
Location:
2023 – Page 6
2024 – Page 6
Reason for Change:
Updated based on policy changes for the 2024 performance year.
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content: Who
Subgroups registered to report an MVP can request reweighting through the QPP
Service Center; subgroup reweighting requests will be superseded by any reweighting
approved for their affiliated group. See Slide 11 for additional information.
2024 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content: Who
Subgroups will inherit any reweighting applied to their affiliated group; they can’t request
reweighting independent of their affiliated group’s status. See Slide 11 for additional
information.

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Change #3:
Location:
2023 – Page 6
2024 – Page 6
Reason for Change:
Updated based on policy changes for the 2024 performance year.
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content: N/A
2024 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content: Why
The 2019 Coronavirus (COVID-19) PHE ended on May 11, 2023. We’re not accepting
applications due to COVID-19 for the 2024 performance year.
Change #4:
Location:
2023 – Page 6
2024 – Page 6
Reason for Change:
Updated dates for new performance year.
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.
2024 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 December 31, 2024.

2

Change #5:
Location:
2023 – Page 7
2024 – Page 7
Reason for Change:
Updated dates for new performance year.
2023 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 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’ll 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).
2024 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 2024 MIPS performance
period would be equal to the performance threshold and you would receive a neutral
payment adjustment in 2026.
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 2024 MIPS performance
period would be equal to the performance threshold and you would receive a neutral
payment adjustment in 2026.
3

You’ll 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 2024 Automatic Extreme and Uncontrollable Circumstances Fact
Sheet (PDF, 323KB) 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 of Promoting
Interoperability, review the 2024 Promoting Interoperability Quick Start Guide
(PDF, 1MB).
Change #6:
Location:
2023 – Page 9
2024 – Page 9
Reason for Change:
Clarify performance category reweighting if all four categories are approved for an
Extreme and Uncontrollable Circumstances Exception.
2023 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Overview
Content: You’re planning to report traditional MIPS or registered to report an MVP. You
submit an application to have all 4 performance categories reweighted, but later
determine you’re able to report the improvement activities and Promoting Interoperability
performance categories.
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content: You’re planning to report traditional MIPS or registered to report an MVP. You
submit an application to have all 4 performance categories reweighted to 0%, but later
determine you’re able to report the improvement activities and Promoting Interoperability
performance categories.

4

Change #7:
Location:
2023 – Page 11
2024 – Page 11
Reason for Change:
Updated based on policy changes for the 2024 performance year.
2023 Final Document text:
Section: Extreme and Uncontrollable Circumstances Exception Application Overview
Content:
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.
2024 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Overview
Content:
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, it will only override performance category reweighting for the
subgroup.
• Subgroups can’t submit a MIPS EUC Exception application as outlined in this guide.

5

Change #8
Location:
2023 – Page 12
2024 – Page 12
Reason for Change:
Updated based on policy changes for the 2024 performance year.
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)
2024 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:
• ACO Realizing Equity Access and Community Health (ACO REACH)
• Advancing All-Payer Health Equity Approaches and Development (AHEAD) Model*
• Bundled Payments for Care Improvement (BPCI) Advanced Model
• Comprehensive Care for Joint Replacement (CJR) Payment Model
• Enhancing Oncology Model (EOM)
• Guiding an Improved Dementia Experience (GUIDE) Model
• Kidney Care Choices (KCC)
• Making Care Primary (MCP)
• Maryland Total Cost of Care Model
• Medicare Shared Savings Program
• Primary Care First (PCF)
• States AHEAD Model - Hospital Track*
• Value in Opioid Use Disorder Treatment (ViT)
• Vermont Medicare ACO Model
*State-by-state determination.

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Change #9:
Location:
2023 – Page 16
2024 – Page 16
Reason for Change:
Updated title of linked document to align with current performance year.
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Frequently Asked Questions
Content: 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.
2024 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Frequently Asked Questions
Content: 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 2024 MIPS Data Validation Criteria Guide (ZIP, 2MB) for
information on the data validation and audit process.
Change #10:
Location:
2023 – Page 22
2024 – Page 22
Reason for Change:
Updated to align with current policy.
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.
2024 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Application Steps
Content: Note: If reporting an MVP with a subgroup, you will inherit any reweighting
approved for your affiliated group. Subgroups can’t request reweighting independent of
their affiliated group’s status.

7

Change #11:
Location:
2023 – Page 26
2024 – Page 26
Reason for Change:
Updated to align with current policy.
2023 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Application Steps
Content: N/A
2024 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Application Steps
Content: Note: The 2019 COVID-19 PHE ended on May 11, 2023. We’re no longer
accepting applications due to COVID-19 for the 2024 performance year.
Change #12:
Location:
2023 – N/A
2024 – Page 27
Reason for Change:
Updated to align with current policy.
2023 Final Document text:
Section: N/A
Content: N/A
2024 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Application Steps
Content: Step 8: Enter the Extreme and Uncontrollable Circumstances Event Type
Cont.
Applications due to the Change Healthcare Cyberattack in late February should include
“Ransom/Malware” as the Event Type. Once selected, confirm that the ransom/malware
event pertained to the Change Healthcare Cyberattack.
Note: A Cybersecurity incident affecting Change Healthcare occurred in late February
2024, impacting healthcare operations around the country.
*The screenshots included in this user guide were based on the QPP test environment.
Because we are always working to incorporate feedback and improve the experience,
there may be differences between these screenshots and what you see on the QPP
website.

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Change #13:
Location:
2023 – Page 27
2024 – Page 28
Reason for Change:
Updated title of linked document to align with current performance year.
2023 Final Document text:
Section: 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.
2024 Final Document text:
Section: MIPS Extreme and Uncontrollable Circumstances Exception Application
Process: Application Steps
Content:
See our 2024 MIPS Data Validation Criteria for information on the data validation and
audit process.
Change #14:
Location:
2023 – Page 35
2024 – Page 36
Reason for Change:
Updated dates for new performance year.
2023 Final Document text:
Section: Appendices
Content: 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. (Small practices should refer to Appendix A2.)
2024 Final Document text:
Section: Appendices
Content: 2024 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 2024 performance category weights and reweighting
policies that CMS will apply to clinicians, groups, and virtual groups reporting traditional
MIPS or MVPs. (Small practices should refer to Appendix A2.)

9

Change #15:
Location:
2023 – Page 36
2024 – Page 37
Reason for Change:
Updated dates for new performance year.
2023 Final Document text:
Section: Appendices
Content: 2023 Performance Year MIPS Performance Category Weight Redistribution
Policies for Individual Clinicians, Groups, Virtual Groups, and APM Entities Reporting
Traditional MIPS or MVPs (Continued)
2024 Final Document text:
Section: Appendices
Content: 2024 Performance Year MIPS Performance Category Weight Redistribution
Policies for Individual Clinicians, Groups, Virtual Groups, and APM Entities Reporting
Traditional MIPS or MVPs (Continued)
Change #16:
Location:
2023 – Page 37
2024 – Page 38
Reason for Change:
Updated dates for new performance year.
2023 Final Document text:
Section: Appendices
Content: 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.
2024 Final Document text:
Section: Appendices
Content: 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.

10

Change #17:
Location:
2023 – Page 38
2024 – Page 39
Reason for Change:
Updated dates for new performance year and add clarifying language on payment
adjustments.
2023 Final Document text:
Section: Appendices
Content: MIPS Performance Category Weight Redistribution Policies Under Traditional
MIPS Finalized for the 2024 Performance Year: Small Practices (Continued)
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: MIPS Performance Category Weight Redistribution Policies Under Traditional
MIPS Finalized for the 2024 Performance Year: Small Practices (Continued)
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.
Change #18:
Location:
2023 – Page 39
2024 – Page 40
Reason for Change:
Updated dates for new performance year.
2023 Final Document text:
Section: Appendices
Content: 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 or MVPs and to
individual clinicians, groups and APM Entities reporting via the APP.
2024 Final Document text:
Section: Appendices
Content: 2024 Performance Year MIPS Performance Category Weight Redistribution
Policies for APM Entities and APM Participants Reporting the APP
The table below illustrates the 2024 performance category weights and reweighting
policies that CMS will apply to APM Entities reporting traditional MIPS or MVPs and to
individual clinicians, groups and APM Entities reporting via the APP.
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