With the release of the 2023 Proposed MIPS and QPP Rule, we are highlighting potential changes that could impact practices if finalized. This week, we are focusing on Advanced Alternative Payment Model (APM) participants and what changes are being proposed for them. In this blog, we will review the major potential changes for APM participants in the 2023 proposed rule as well as provide a reminder for those who achieved Qualifying Participant (QP) status to ensure that they are able to receive payment.
2023 Proposed Changes
Promoting Interoperability Reporting
CMS is proposing to allow APM Entities the option to report Promoting Interoperability (PI) at the entity level, if they choose. Up until now, reporting has been completed for each individual participant TIN for the PI category. However, both Quality and Improvement Activity data is aggregated at the entity level for reporting currently, so this proposed change is not revolutionary and instead could potentially provide more consistency for reporting standards and expectations for APMs.
If finalized, for the 2023 reporting period, the following considerations should be made:
Distribution of APM Incentive Payments to Providers
When CMS is unable to complete APM Incentive payments, they are required to post a notice in the Federal Register to provide an opportunity for providers to clarify or update their payment information. Under current policy, the cut-off date for providers to update their information is November 1 of each payment year or 60 days from the date on which CMS makes the initial round of APM Incentive Payments for such year, whichever is later.
CMS is proposing to change the deadline to September 1 of the payment year or 60 days from the date on which CMS makes the initial round of payments, whichever is later. This proposed change is due to CMS' need for additional time to process payments and is a reflection of their ability to provide earlier notification to providers regarding their inability to complete payment.
Nominal Amount Standard
This proposal only directly impacts the APM Entity, not the participating clinicians. When the QPP was established, CMS put in place an 8% nominal amount standard, but said that it would need to be reevaluated after 2020. The "nominal amount standard" defines the the minimum total amount of the average estimated total Medicare Parts A and B revenues of all providers and suppliers participating in the APM Entity that the entity must put at risk. CMS is proposing to maintain the nominal amount standard at 8% for all future years.
Requests for Information for Potential Future Changes
QP Determinations at the Individual Eligible Clinician Level
CMS is requesting information on sunsetting the use of APM Entity-level QP determinations and instead making QP determinations at the individual eligible clinician level only.
Transition from APM Incentive to QP Physician Fee Schedule (PFS) Conversion Factor
As the 5% lump sum bonus ends in the 2022 performance year, CMS is requesting information regarding the gap in statutory financial incentives and the difference in potential incentives between QPs and MIPS eligible clinicians in future years.
2025 Payment Year Gap in Incentives
QP PFS Conversion Factor Inadequacy compared to MIPS Positive Payment Adjustment
2022 QP Notice for APM Incentive Payment
While we have the attention of APM participants, we wanted to call to attention that CMS is attempting to contact providers for whom they are currently unable to complete 2020 performance year/2022 payment year APM Incentive compensation transactions. To ensure that you receive proper payment, please complete the following steps.
Next Steps
If you have any questions on this, let us know!