Is your advanced alternative payment model recognized by CMS?

Medicare’s Quality Payment Program offers two tracks for Medicare physician payment: the Merit-based Incentive Payment System (MIPS) and the advanced alternative payment model (APM). The Centers for Medicare & Medicaid Services (CMS) this month published a table displaying the APMs that it operates. In the table, CMS identifies which of those APMs it has determined to be MIPS APMs or advanced APMs.

To be an advanced APM, an APM must meet the following three criteria:

1. Require participants to use certified electronic health record technology;
2. Pay covered professional services based on quality measures comparable to those used in the quality performance category of MIPS; and
3. Either be a Medical Home Model expanded under CMS Innovation Center authority or require participating APM entities bear more than a nominal amount of financial risk for monetary losses.

Although no Medical Home Models have been expanded under CMS Innovation Center authority, CMS applies a different advanced APM financial risk criterion to Medical Home Models. Also, MIPS-eligible clinicians participating in Medical Home Models automatically receive the full score for the MIPS improvement activities performance category.

MIPS APMs are APMs that don’t meet the “advanced” criteria but otherwise include MIPS-eligible clinicians and hold their participants accountable for the cost and quality of care provided to Medicare beneficiaries. MIPS-eligible clinicians in MIPS APMs have special MIPS reporting requirements and are scored using the “APM scoring standard.”

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians