A Merit-Based Incentive Payment System (MIPS) Alternative Payment Model (APM) is a new concept that allows clinicians to choose to be evaluated for their performance under MIPS by using a special scoring standard specific to a certain APM. The scoring standard is designed to account for activities already required by the APM. Clinicians in an Advanced APM that become a Qualifying APM Participant (QP) are excluded from the MIPS reporting requirements and payment adjustment for the year. Clinicians found to be a Partial QP can choose whether to participate in MIPS and a MIPS APM.
To be considered a MIPS APM, an APM must:
- Participate in the APM under an agreement with the Centers for Medicare and Medicaid Services (CMS)
- Include at least one MIPS clinician on a Participation List
- Base payment incentives on performance (either at the APM entity or clinician level) on cost/utilization and quality measures
Advantages of MIPS APM Participation
- Preferential scoring with 0% cost domain weighting, automatic 100% credit for practice improvement activities and quality measure sets based on the MIPS APM in which the clinician is participating
- Simplified reporting, as quality reporting is required for APM participation
- Six years to prepare to adopt downside financial risk while gaining experience with managing risk through MIPS APM participation
The following models are considered MIPS APMs for 2018:
- Comprehensive ESRD Care Model (Large Dialysis Organization arrangement)
- Comprehensive ERSD Care Model (Non-LDO Arrangement)
- Comprehensive Primary Care Plus (CPC+)
- Medicare Shared Savings Program – Track 1+
- Medicare Shared Savings Program – Track 2
- Medicare Shared Savings Program – Track 3
- Next Generation ACO Model
- Oncology Care Model Two-Sided Risk Arrangement
- Oncology Care Model One-Sided Risk Arrangement
- Vermont All-Payer ACO Model
The APM scoring standard does not apply to clinicians in an APM that includes only facilities as participants. Clinicians participating in an Advanced APM that is also a MIPS APM, but does not qualify to be either a QP or Partial QP, will have the APM scoring standard applied.
CMS applies the APM scoring standard if the previously listed criteria is met and if the clinicians are participating in a MIPS APM on at least one of four "snapshot" dates: March 31, June 30, Aug. 31 and Dec. 31. Clinicians participating in a MIPS APM that are not on the APM Participation List on one of the snapshot dates must participate using the MIPS track.
APM Scoring StandardThe weights assigned to the MIPS performance categories under the APM scoring standard may differ from regular MIPS performance category weights.
- For MIPS APMs that are under the Medicare Shared Savings Program or Next Generation ACO Model, the quality measures the APM requires are used to determine a MIPS Quality performance category score.
- For the Medicare Shared Savings Program and the Next Generation ACO Model the Quality performance category is weighted at 50 percent for the 2018 performance period.
- For all other MIPS APMs, the Quality performance category weight is zero for the 2018 performance period and no score is calculated for this category.
- MIPS APM participants are exempt from the Cost category, so the Cost category for MIPS APMs is weighted at zero percent for the 2018 performance period.
- For the 2018 performance period, CMS assigns all MIPS APMs maximum points for the Improvement Activities performance category.
- Each MIPS clinician in the MIPS APM will receive the assigned score for the Improvement Activities performance category and will not have to submit improvement activities data for MIPS.
- The Improvement Activities weight for CY 2018 performance period for the Medicare Shared Savings Program and the Next Generation ACO model is 20 percent.
- For all other MIPS APMs, the Improvement Activities performance category is weighted at 25 percent for the 2018 performance period.
Advancing Care Information
- All MIPS clinicians will report data for the Advancing Care Information (ACI) performance category per general MIPS requirements.
- The Medicare Shared Savings Program ACO participant Tax Identification Number (TIN) scores for the ACI category will be combined as a weighted average based on how many MIPS clinicians are in each TIN. This will result in one ACO group score for the ACI performance category that applies to all MIPS clinicians in the ACO.
- For the Next Generation ACO model and all other MIPS APMs under the APM scoring standard, MIPS clinicians in the APM report on the ACI performance category through either a group TIN or individual reporting.
- The ACI performance category for the 2018 performance period is weighted at 30 percent for the Medicare Shared Savings Program and the Next Generation ACO model MIPS APMs.
- For all other MIPS APMs this performance category is weighted at 75 percent.
- All MIPS clinicians scored under the APM scoring standard will receive a MIPS final score based on the APM entity's combined performance. This lowers the reporting burden for clinicians by aligning the reporting requirements for MIPS and the APM's reporting requirements.
- If a clinician participates in two or more MIPS APMs, CMS uses the highest final score to calculate the MIPS payment adjustment.
Quick Tips to Prepare for MIPS APM Participation
- Find out if the MIPS APM entity (such as a physician group practice or hospital) you belong to already participates in one or more APMs. Search for your facility using this tool.
- Determine if the APM your organization participates in is considered a MIPS APM.
- Ask your practice/hospital administrator if you meet the requirements to be included on the APM Participation List.