Advanced Alternative Payment Models (APMs)
In the first performance year (2017) Medicare anticipates that a minority of eligible clinicians will be recognized as "Qualified Participants" (QPs) in Advanced Alternative Payment Models (APMs). QPs are exempt from the MIPS payment adjustments and receive a 5% incentive payment on Part B Medicare payments for the first 5 years of the Quality Payment Program.
CMS identified 6 examples of Advanced APMs in the proposed rule:
CMS has proposed updating the list of approved advanced APMs on an annual basis. For the first two performance years (2017 and 2018) advanced APMs will need to those developed by Medicare. However, in 2019 clinicians could qualify for incentive payments based, as least in part, by private insurers and state Medicaid programs.
MACRA also required CMS to review physician-focused payment models that may be submitted for review by the newly formed Physician-Focused Payment Technical Advisory Committee. This group will evaluate proposals and then determine whether to recommend them for approval by CMS.
Eligible Clinicians will not know if they have met the requirements of being a Qualified Participant in an advanced APM for 2017 until 2018. If the EC does not qualify as an QP, they will be subject to the MIPS program. For this reason all ECs are encouraged to engage in MIPS to avoid potential negative payment adjustments in 2019.