Crosswalk: Appendix B1

All-Payer Payer Initiated Submission Form
CY 2023 Final versus CY 2024 Final
Burden impact: The changes to this form reflect policies 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 18
Reason for Change:
Alignment with current year.
CY 2023 Final Rule text:
2023 for the 2024
CY 2023 Final Rule text:
2024 for the 2025
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Change #2:
Location: Page 1, Line 24
Reason for Change:
Alignment with current year.
CY 2023 Final Rule text:
2023 for the 2024
CY 2023 Final Rule text:
2024 for the 2025
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Change #3:
Location: Page 1, Line 29
Reason for Change:
Alignment with current year.
CY 2023 Final Rule text:
2023 for the 2024
CY 2023 Final Rule text:
2024 for the 2025
*****
Change #4:
Location: Page 8, Line 42
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)? [Y/N]

For purposes of this Form, the APM Entity is the practitioner or group of practitioners
that participates in the payment arrangement.
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 14, Line 42
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)? [Y/N]
For purposes of this Form, the APM Entity is the practitioner or group of practitioners
that participates in the payment arrangement.
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]
*****
Change #6:
Location: Page 20, Line 36
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)? [Y/N]
For purposes of this Form, the APM Entity is the practitioner or group of practitioners
that participates in the payment arrangement.
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]