Alternative Payment Models under the Quality Payment Program

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One way that clinicians can participate in the Medicare Quality Payment Program is through an Advanced Alternative Payment Model, or APM. (The other option is the Merit-Based Incentive Program, or MIPS.)

Qualifying Participants in Advanced APMs

Only Qualifying Participants (QPs) in Advanced APMs will be eligible for the 5% Medicare incentive payment offered under this track. If you are determined to be a QP in an Advanced APM, you are not only eligible for this higher incentive payment, but CMS also will refrain from scoring your performance under MIPS.

To be considered a QP during performance year 2021, a clinician must participate in an Advanced APM, which bear financial risk for monetary losses, use MIPS-comparable quality measures, and rely on certified EHR technology (CEHRT). The APM Entity group also must receive at least 50 percent of Medicare Part B payments or see at least 35 percent of Medicare patients through an Advanced APM entity during the QP performance period (January 1 - August 31). An APM entity group may also become a QP through the "All-Payer and Other Payer Option", which is a combination of Medicare and non-Medicare payer arrangements such as private payers and Medicaid.

To access more information about the QP track, including which models fall under the definition of “Advanced APMs,” how CMS determines QP status, and how CMS calculates and disburses the 5% QP Incentive Payment, STS members may contact advocacy@sts.org for an additional resource guide.

Keep in mind that the number of clinicians that qualify as QPs is still relatively small compared to those who qualify for the MIPS track of the QPP, particularly among specialists for which few Advanced APMs are currently available.  

MIPS APMs

Clinicians who participate in certain APMs, known as “MIPS APMs,” but do not satisfy the criteria for being a QP in an Advanced APM, are not eligible for the 5% APM bonus. These clinicians are still required to participate in MIPS, but are offered certain reporting and scoring accommodations to recognize efforts already being made under the APM. For 2021, CMS has made changes to the treatment of these clinicians. Most notably, it retired the APM Scoring Standard and authorized a new APM Performance Pathway.

For more detailed information about MIPS participation options for clinicians in MIPS APMs, STS members may contact advocacy@sts.org for an additional resource guide.

Last updated: 5/28/2021