APM Highlights

Quality Payment Program Year 3: APM Highlights

  • Updating the Advanced APM Certified Electronic Health Record Technology (CEHRT) threshold so that an Advanced APM must require that at least 75% of eligible clinicians in each APM Entity use CEHRT, and for Other Payer Advanced APM, as of January 1, 2020, the number of eligible clinicians participating in the other payer arrangement who are using CEHRT must be 75%.
  • Extending the 8% revenue-based nominal amount standard for Advanced APMs and Other Payer Advanced APMs through performance year 2024.
  • Increasing flexibility for the All-Payer Combination Option and Other Payer Advanced APMs for non-Medicare payers to participate in the Quality Payment Program.
    • Establishing a multi-year determination process where payers and eligible clinicians can provide information on the length of the agreement as part of their initial Other Payer Advanced APM submission, and have any resulting determination be effective for the duration of the agreement (or up to 5 years). We are finalizing this streamlined process to reduce the burden on payers and eligible clinicians.
    • Allowing QP determinations at the TIN level, in addition to the current options for determinations at the APM entity level and the individual level, in instances when all eligible clinicians who have reassigned their billing rights to the TIN are included in a single APM Entity. This will provide additional flexibility for eligible clinicians under the All-Payer Combination Option.
    • Moving forward with allowing all payer types to be included in the 2019 Payer Initiated Other Payer Advanced APM determination process for the 2020 QP Performance Period.
  • Streamlining the definition of a MIPS comparable measure in both the Advanced APM criteria and Other Payer Advanced APM criteria to reduce confusion and burden among payers and eligible clinicians submitting payment arrangement information to CMS.
  • Clarifying the requirement for MIPS APMs to assess performance on quality measures and cost/utilization.
  • Updating the MIPS APM measure sets that apply for purposes of the APM scoring standard.

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