MIPS: Can I Ignore or Avoid It?

Leigh Page


July 07, 2016

In This Article

Another Way to Be Exempt: Through Advanced APMs

Membership in an advanced APM is another route out of MIPS, but CMS plans to tightly restrict this approach.

According to the proposed rule, the only entities that would be recognized as advanced APMs are those that take on substantial financial risk. These are accountable care organizations (ACOs) in tracks 2 and 3 of the Medicare shared-savings program, next-generation ACOs, entities in the Comprehensive ESRD (end-stage renal disease) Care model in an LDO (large dialysis organization) arrangement, Comprehensive Primary Care Plus entities, and entities in the Oncology Care Model in a two-sided risk arrangement, according to the proposed rule.

This list shuts out track 1 ACOs, which account for about 90% of all ACOs, and many patient-centered medical homes from being designated as advanced APMs. But CMS has added yet more limitations. For clinicians in advanced APMs to become qualified providers (QPs) exempted from MIPS, they would have to earn a minimum of 20% of Medicare payments and have 10% of patients through the advanced APM, CMS says in the proposed rule.

Furthermore, CMS says that even among this group of QPs, many would not qualify as "full QPs," who get an automatic bonus equal to 5% of their Medicare reimbursements. This second tier, called "partial QPs," are those who get 20%-25% of the Medicare payments and 10%-20% of their patients through advanced APMs.

Unable to get the 5% bonus, partial QPs might decide to stay in MIPS, where they might actually earn more money than as full QPs. High-performing MIPS clinicians might earn bonuses of as much as 12% in MIPS. In MIPS, partial QPs have many advantages, such as not having to report certain metrics and getting "favorable weights," according to the proposed rule.


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