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Quality Improvement Manager
Merit-based Incentive Payment System Alternative Payment Models (MIPSs APMs) are a subset of APMs. Participating in a MIPS APM can reduce your MIPS reporting burden so you can focus on patient care and the goals of your APM. While this is an APM, the practice is not excluded from MIPS, but may be scored using a special APM scoring standard. A MIPS APM may also be called an Accountable Care Organizations (ACO), depending on the model.
A practice can find out if they are connected to a MIPS APM using the QPP eligibility lookup.
MIPS APMs are those APMs that meet these three criteria:
Like MIPS, clinicians in a MIPS APM will receive a score between 0-100 based on performance in the MIPS performance categories (Quality, Improvement Activities, Promoting Interoperability and Cost). However, the weights assigned to each category under the APM scoring standard might be different from the regular MIPS performance category weights. In 2020, CMS finalized allowing MIPS eligible clinicians participating in MIPS APMs to report on MIPS quality measures in a manner similar to the established policy for the Promoting Interoperability performance category. CMS will allow MIPS eligible clinicians in MIPS APMs to receive a score for the Quality performance category through either individual or TIN-level reporting based on the generally applicable MIPS reporting and scoring rules for the Quality performance category. CMS will apply a minimum score of 50 percent, or an ‘‘APM Quality Reporting Credit’’ under the MIPS Quality performance category for certain APM entities participating in MIPS, where APM quality measures are not used for MIPS purposes. In cases where this credit is applied, it will be added to the MIPS Quality performance score, subject to a cap of 100 as a total score for the Quality performance category.
If you’re in a MIPS APM and you’re included in MIPS, you may be scored using the APM scoring standard, which:
If the clinician scores above the threshold for a given year, a bonus will be provided. A penalty will be applied if the score is below the threshold. CPSs at the performance threshold receive a neutral MIPS adjustment factor. The general MIPS payment adjustment details discussed above also apply to the MIPS APM Scoring Standard.
The APM scoring standard is designed to account for activities already required by the APM. For example, the APM scoring standard eliminates the need for MIPS clinicians to duplicate submission of Quality and Improvement Activity performance category data and allows them to focus instead on the goals of the APM.
Each MIPS APM or ACO model will have minor differences. It is important for practices to confirm the model type to understand the requirements.
Some of the models are listed below:
Medicare Shared Savings Program (MSSP) - The Shared Savings Program offers different participation options (tracks) that allow ACOs to assume various levels of risk.Starting in 2019, the options are listed under BASIC and Enhanced tracks.
Next Generation Accountable Care Organization - NextGen ACO - The Next Gen ACO model allows ACOs to assume higher levels of financial risk and reward than under the traditional Medicare Shared Savings Program (MSSP) Tracks.
Oncology Care Model - one-sided risk (OCM) - The OCM is a 5-year model focused on increasing the coordination of oncology care through financial and performance accountability for chemotherapy episodes of care. Radiation oncologists within the OCM must still collect data on their patients regardless of whether they fall into the OCM episode. The radiation data will still be submitted through the OCM by the groups administrator along with the OCM data. There is also a two-sided risk model that is considered an Advanced APM.
MSSP Web Interface measures reported through the ACO, using MSSP quality benchmarks. Earn up to 10 points per measure based on performance vs. benchmark. Bonus points are awarded for reporting high priority measures contained in the Web Interface measure set. Measures are averaged to compile a score for this category.
Max Possible Points: 210+ points
Percentage of Overall Score: 50%
Clinicians must report all 11 required Base Score measures to earn credit in this category. Additionally, clinicians must report on a select amount of measures of their choice under the Performance Score for up to 10 points per measure. One bonus point will be awarded for reporting an additional public health registry measure beyond the minimum required. Base Score, Performance Score and bonus points are totaled. Any total score over 100 points earns full credit in this category.
All MIPS eligible clinicians participating in the APM Entity group will submit according to MIPS requirements. Performance will be assessed as a group through the billing TINs associated with the ACO for MSSP. All of the ACO participant group billing TIN scores will be aggregated as a weighted average to yield one ACO group score.
Next Generation ACOs
All MIPS eligible clinicians participating in the APM Entity group submit as individuals according to MIPS requirements. All of the MIPS eligible clinician scores will be aggregated and averaged to yield one ACO score. An ACO eligible clinician who does not report this category contributes a score of zero.
Max Possible Points: 100 points
(Base Score= 50 points
Performance Score= 80 points)
Percentage of Overall Score: 50%
Each clinician will be required to report one-to-three approved CPIAs to earn full credit in this category. Each activity is worth 10 points; however certain activities are worth 20 points for being considered “high value.” The clinician must earn at least 60 points to be awarded full credit in this category. ACOs will be given 30 points in this category automatically for their participation in the ACO.
Max Possible Points: 60 points
Percentage of Overall Score: 20%
CMS will not calculate a cost score for ACOs under the MIPS APM Scoring Standard
Max Possible Points: N/A
Percentage of Overall Score: 0%