Crosswalk: Appendix H1

MIPS Promoting Interoperability Performance Category 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 MIPS Promoting Interoperability Performance Category Hardship Exception
Application Guide
2023 Final Document text:
Title: 2023 MIPS Promoting Interoperability Performance Category Hardship Exception
Application Guide
Change #2:
Location:
2022 – Page 2
2023 – Page 2
Reason for Change:
Removed part of section title
2022 Final Document text:
Section: Table of Contents
Content: MIPS Promoting Interoperability Performance Category Hardship Exception
Information for Individuals, Groups and Virtual Groups
2023 Final Document text:
Section: Table of Contents
Content: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Change #3:
Location:
2022 – Page 2
2023 – Page 2
Reason for Change:

Removed section with additional resources and glossary therefore the table of contents
was updated.
2022 Final Document text:
Section: Table of Contents
Content: Help, Resources, Glossary, and Version History
2023 Final Document text:
Section: Table of Contents
Content: Help and Version History
Change #4:
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 MIPS
Promoting Interoperability Performance Category Hardship 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 MIPS
Promoting Interoperability Performance Category Hardship Exception application and
provide step-by-step instructions on how to complete the application.
Change #5:
Location:
2022 – Page 6
2023 – Page 6
Reason for Change:
Updated to account for program changes.
2022 Final Document text:
Section: Overview
Content: Who
Individual clinicians, groups, and virtual groups reporting via traditional MIPS or the APM
Performance Pathway (APP).
• Third party intermediaries can submit an application with permission from the clinician
or practice.
Some clinicians, groups and virtual groups automatically qualify for reweighting of the
Promoting Interoperability performance category. If you qualify for automatic
reweighting, you don’t need to apply for a MIPS Promoting Interoperability Hardship

Exception.
• See Appendix A for information about the clinicians, groups, and virtual groups that
automatically qualify for reweighting of this performance category.
2023 Final Document text:
Section: Overview
Content: Who
Individual clinicians, groups, and virtual groups reporting via traditional MIPS, MIPS
Value Pathways (MVPs) or the APM Performance Pathway (APP).
• Third party intermediaries can submit an application with permission from the clinician
or practice.
Some clinicians, groups and virtual groups automatically qualify for reweighting of the
Promoting Interoperability performance category. If you qualify for automatic
reweighting, you don’t need to apply for a MIPS Promoting Interoperability Hardship
Exception.
• See Appendix A for information about the clinicians, groups, and virtual groups that
automatically qualify for reweighting of this performance category.

Change #6:
Location:
2022 – Page 6
2023 – Page 6
Reason for Change:
Updated dates for new year
2022 Final Document text:
Section: Overview
Content: When
Now through January 3, 2023, at 8 p.m. ET.
2023 Final Document text:
Section: Overview
Content: When
The Promoting Interoperability Hardship Exception application will close at 8 p.m. ET on
January 2, 2024.
Change #7:
Location:
2022 – Page 7
2023 – Page 7
Reason for Change:
Updated section break title in alignment with changes to table of contents

2022 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information for Individuals, Groups and Virtual Groups
Content: MIPS Promoting Interoperability Performance Category Hardship Exception
Information for Individuals, Groups and Virtual Groups
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: MIPS Promoting Interoperability Performance Category Hardship Exception
Information

Change #8:
Location:
2022 – Page 8
2023 – Page 8
Reason for Change:
Updated because the policy was no longer new.
2022 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information for Individuals, Groups and Virtual Groups
Content: New: Small practices now qualify for automatic reweighting.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: Reminder: Small practices qualify for automatic reweighting.
Change #9
Location:
2022 – Page 8
2023 – Page 8
Reason for Change:
Updated to account for new policy.
2022 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information for Individuals, Groups and Virtual Groups
Content: You will complete the hardship exception application at the level for which you
will report data to MIPS.
• If you are reporting data at the individual level, complete the hardship exception
application at the individual level.
• If you are reporting data at the group level, complete the hardship exception application
at the group level.
• Note, a group hardship exception application will only apply at the group level.

• If your practice is participating in MIPS at the individual level, don’t complete the
hardship exception application at the group level. You will complete the hardship
exception application at the individual level for each clinician (who doesn’t
automatically qualify for reweighting) to be considered for reweighting.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: You will complete the hardship exception application at the level for which you
will report data to MIPS.
• If you are reporting data at the individual level, complete the hardship exception
application at the individual level.
• If you are reporting data at the group level, complete the hardship exception application
at the group level.
• Note, a group hardship exception application will only apply at the group level.
• If your practice is participating in MIPS at the individual level, don’t complete the
hardship exception application at the group level. You will complete the hardship
exception application at the individual level for each clinician (who doesn’t
automatically qualify for reweighting) to be considered for reweighting.
o If you’re reporting as an MVP as a subgroup, the group level Hardship Exception
will apply to the subgroup participants.

Change #10:
Location:
2022 – Page 8
2023 – Page 8
Reason for Change:
Updated because the policy was no longer new.
2022 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information for Individuals, Groups and Virtual Groups
Content: Starting with performance year 2022, small practices qualify for automatic
reweighting of the Promoting Interoperability performance category.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: Small practices qualify for automatic reweighting of the Promoting
Interoperability performance category.

Change #11:
Location:
2022 – Page 8

2023 – Page 9
Reason for Change:
Updated title of linked document to align with current performance year.
2022 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information for Individuals, Groups and Virtual Groups
Content:
You aren’t required to submit documentation with your application.
• However, clinicians, groups, and virtual groups should retain documentation of
their circumstances supporting their application for their own records in the event
they’re selected by CMS for data validation or audit. See our 2022 MIPS Data
Validation Criteria (ZIP) for details on the data validation process.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content:
You aren’t required to submit documentation with your application.
• However, clinicians, groups, and virtual groups should retain documentation of
their circumstances supporting their application for their own records in the event
they’re selected by CMS for data validation or audit. See our 2023 MIPS Data
Validation Criteria (ZIP) for details on the data validation process.

Change #12:
Location:
2022 – Page 9
2023 – Page 9
Reason for Change:
Updated to align with current performance year.
2022 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information for Individuals, Groups and Virtual Groups
Content: You may still be able to report if your electronic health record (EHR) product is
decertified during the 2022 performance year.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: You may still be able to report if your electronic health record (EHR) product is
decertified during the 2023 performance year.

Change #13:

Location:
2022 – Page 11
2023 – Page 11
Reason for Change:
Acronym previously spelled out.
2022 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information for Individuals, Groups and Virtual Groups
Content: A MIPS Promoting Interoperability performance category hardship exception
doesn’t exempt you from reporting on any certified EHR technology (CEHRT) activities
required for participation in your APM.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception
Information
Content: A MIPS Promoting Interoperability performance category hardship exception
doesn’t exempt you from reporting on any CEHRT activities required for participation in
your APM.

Change #14:
Location:
2022 – Page 13
2023 – Page 13
Reason for Change:
Added new option for contacting the QPP service center and rearranged order of contact
options.
2022 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Frequently Asked Questions
Content:
If you identified an error with your exception application, please 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: [email protected].
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Frequently Asked Questions
Content:
If you identified an error with your exception application, please contact the Quality
Payment Program Service Center by email at [email protected], create a QPP Service
Center ticket, or by phone at 1-866-288-8292 (Monday – Friday, 8 a.m. - 8 p.m. ET).

Change #15:
Location:
2022 – Page 15 (repeats on every page through page 29)
2023 – Page 15 (repeats on every page through 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 Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: *The screenshots included in this user guide were based on the QPP test
environment. Because we are always working to incorporate
feedback and improve experience, there may be differences between these screenshots
and what you see on qpp.cms.gov.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: *The screenshots included in this user guide were based on the QPP test
environment. Because we are always working to incorporate
feedback and improve experience, there may be differences between these screenshots
and what you see on the QPP website.

Change #16:
Location:
2022 – Page 16
2023 – Page 16
Reason for Change:
Updated deadline.
2022 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: You can create and submit a new exception request until 8 p.m. ET on
January 3, 2023.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: You can create and submit a new exception request until 8 p.m. ET on January
2, 2024.
Change #17:
Location:
2022 – Page 16

2023 – Page 16
Reason for Change:
Updated title of linked resource to account for new year.
2022 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: Note: You don’t need to submit supporting documentation with your
application. However, you should retain documentation of the circumstances supporting
your application for your own records in case you are selected by CMS for data
validation or an audit. See our 2022 MIPS Data Validation Criteria Guide (ZIP) for details
on the data validation process.
2023 Final Document text:
Section: MIPS Promoting Interoperability Performance Category Hardship Exception:
Application Steps
Content: Note: You don’t need to submit supporting documentation with your
application. However, you should retain documentation of the circumstances supporting
your application for your own records in case you are selected by CMS for data
validation or an audit. See our 2023 MIPS Data Validation Criteria Guide (ZIP) for details
on the data validation process.
Change #18:
Location:
2022 – Page 30
2023 – Page 30
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 31
2023 – Page 31
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: [email protected].
• 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
[email protected], create a QPP Service Center ticket, or by phone at 1-866-288-8292
(Monday through Friday, 8 a.m. - 8 p.m. ET).
• People who are deaf or hard of hearing can dial 711 to be connected to a TRS
Communications Assistant.

Change #20:
Location:
2022 – Page 32
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: Additional Resources
The QPP 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 MIPS Promoting Interoperability Quick Start Guide (PDF)
• 2022 MIPS Promoting Interoperability User Guide (PDF)
• 2022 Extreme and Uncontrollable Circumstances Exception Application Guide
2023 Final Document text: N/A

Change #21:
Location:
2022 – Page 34
2023 – Page 33
Reason for Change:
Updated section title for grammar
2022 Final Document text:
Section: Appendix
Content: Appendix
2023 Final Document text:
Section: Appendices
Content: Appendices

Change #22:
Location:
2022 – Page 35
2023 – Page 34
Reason for Change:
Updated information to align with program changes.
2022 Final Document text:
Section: Appendix
Content:
You have one of these Special Statuses:
• (New) Small Practice;
• Ambulatory Surgical Center (ASC)-based;
• Hospital-based; or
• Non-patient facing
You are one of these clinician types:
• (New) Clinical social worker
• Physician assistant
• Nurse practitioner
• Clinical nurse specialist
• Certified registered nurse anesthetist
• Physical therapist
• Occupational therapist
• Qualified speech-language pathologist
• Qualified audiologist
• Clinical psychologist
• Registered dietitian or nutrition professional
2023 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
You are one of these clinician types:
• Clinical social worker
• Physical therapist
• Occupational therapist
• Qualified speech-language pathologist
• Qualified audiologist
• Clinical psychologist
• Registered dietitian or nutrition professional

Change #23:
Location:
2022 – Page 36
2023 – Page 35
Reason for Change:
Updated title and performance year references to align with current performance year.
2022 Final Document text:
Section: Appendix
Content:
Appendix B. MIPS Performance Category Weight Redistribution Policies Under
Traditional MIPS Finalized for the 2022 Performance Year: Individual Clinicians,
Groups and Virtual Groups
The table below illustrates the 2022 performance category weights and reweighting
policies that CMS will apply to clinicians, groups, and virtual groups reporting via
traditional MIPS.
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 2024 payment year.
2023 Final Document text:
Section: Appendices
Content:
Appendix B. MIPS Performance Category Weight Redistribution Policies Under
Traditional MIPS Finalized for the 2023 Performance Year: Individual Clinicians,
Groups and Virtual Groups
The table below illustrates the 2023 performance category weights and reweighting
policies that CMS will apply to clinicians, groups, and virtual groups reporting via
traditional MIPS.
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 2025 payment year.

Change #24:
Location:
2022 – Page 36
2023 – Page 35

Reason for Change:
Updated reference to later appendix (added a new appendix C in 2023)
2022 Final Document text:
Section: Appendix
Content: Refer to Appendix C for reweighting policies that apply to APM Entities.
2023 Final Document text:
Section: Appendices
Content: Refer to Appendix D for reweighting policies that apply to APM Entities.

Change #25:
Location:
2022 – Page 39
2023 – Page 40
Reason for Change:
Updated appendix title and copy for new performance year.
2022 Final Document text:
Section: Appendix
Content:
Appendix C. MIPS Performance Category Weight Redistribution Policies for APM
Entities and the APP Finalized for the 2022 Performance Year
The table below illustrates the 2022 performance category weights and reweighting
policies that apply to individual clinicians, groups and APM Entities reporting the APP.
2023 Final Document text:
Section: Appendices
Content:
Appendix D. MIPS Performance Category Weight Redistribution Policies for APM
Entities and the APP Finalized for the 2023 Performance Year
The table below illustrates the 2022 performance category weights and reweighting
policies that apply to individual clinicians, groups and APM Entities reporting the APP.