MIPS APMs are those APMs that meet these three criteria:

• The practice participates in the APM under an agreement with CMS;
• The APM requires that practice include at least one MIPS clinician on a Participation List; and
• The APM bases payment incentives on performance (either at the group or clinician level) on cost/utilization and quality measures.

A practice must be actively participating in a MIPS APM on at least one of three “snapshot” dates: March 31, June 30 or August 31. If a practice participates in a MIPS APM but aren’t on the APM Participation List on one of the three snapshot dates, the practice won’t be scored using the APM scoring standard and should instead report to MIPS according to the generally applicable MIPS requirements, either as an individual or as a group.
 
For MSSP, all MIPS-eligible clinicians who bill through the Tax Identification Number (TIN) of an ACO participant are participating in the ACO (the ACO = the APM Entity). However, a clinician must be listed as part of the APM Entity as of December 31 of the performance year in order to be counted as participating in the ACO for the purposes of the MIPS APM Scoring Standard. The list below includes some MIPS APMs for the 2020 performance year that might apply to radiation oncology practices:

• Medicare Accountable Care Organization (ACO) Track 1+ Model
• Medicare Shared Savings Program (SSP) ACOs — Track 1
• Medicare Shared Savings Program ACOs — Track 2
• Medicare Shared Savings Program ACOs — Track 3
• Next Generation ACO Model
• Oncology Care Model (OCM) (one-sided risk arrangement)
• Oncology Care Model (OCM) (two-sided risk arrangement)
• Vermont Medicare ACO Initiative (as part of the Vermont All-Payer ACO Model)

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:

• Is designed to account for activities already required by the APM;
• Eliminates the need for MIPS eligible clinicians to duplicate the submission of certain quality and improvement activities data.

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.