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Heads Up: Changes for APMs in 2023


CMS QPP 2023 APM

2022 is the final performance year that CMS is offering a 5% lump sum incentive to clinicians and practices who receive Qualifying Participant (QP) status in an Advanced Alternative Payment Model (APM). In this blog, we'll review why this change is happening, what you need to know about it, and what your next steps should be if this impacts you or your practice. 

Why is the incentive structure changing?

This change has been anticipated as part of the design of Advanced APMs. Those participating in Advanced APMs have received 5% lump sum bonuses and will receive it for the performance year 2022 as well. However, 2022 is the last performance year for which the lump sum bonus will be rewarded.

Beginning with the 2024 performance year/2026 payment year those in Advanced APMs will begin to have an increased fee schedule update of 0.75% vs. 0.25% for those in MIPS.

Congress left a gap in Advanced APM participation incentives for the 2023 performance year/2025 payment year and there will be neither an increased fee schedule update nor a lump sum bonus. 

What you should know about this change: 

  • The Value in Health Care Act of 2021 being considered in Congress would extend the 5% lump sum bonus through 2024. While this is a long-shot effort to keep participation in Advanced APM's incentivized during this "gap year", it is worth watching out for in the coming months. 

  • Here at MarsdenAdvisors, we generally do not recommend our clients leave their Advanced APM to avoid the 2023 dip in payment incentives. There is no guarantee that re-joining an Advanced APM in 2024 will be feasible.

    • Currently, there are no resources or guidelines for re-joining an Advanced APM. 

    • For specialists, Accountable Care Organizations (ACOs) may be less likely to allow re-joining due to concerns about decreased patient attribution percentages (based on where a patient receives the plurality of their primary care services) causing difficulties in reaching QP thresholds.

  • We recommend that those participating in Advanced APMs prepare for the 2023 "gap year" by planning for the lack of incentives, and budgeting accordingly. 

Next Steps

  • Share this information with your practice colleagues.
  • Contact your Client Success Manager if you have any questions. 
  • If you’re not a MarsdenAdvisors client and you want hands-on, personalized assistance, contact us and we will have your back.

Remember to subscribe to our newsletter to receive alerts about important changes like this in the future! 

Juliette Walle

Written by Juliette Walle

Juliette Walle is a Health Policy Analyst at the consulting firm MarsdenAdvisors.

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