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September 21, 2018

Advanced APMs in 2019

The future of Advanced APMs in the Quality Payment Program remains uncertain—while the incentives have shifted away from the Merit Based Incentive Payment System (MIPS) track and to the A-APM track, the development of new A-APMs has stalled.


While the Innovation Center has been supportive of bundled payments, they have yet to approve many of the models developed by physician groups and other healthcare stakeholders. In recent comments, Secretary Azar has voiced preliminary support for the idea of new mandatory models, and the Administration has suggested that they are looking for A-APM models that have the potential for national scalability and impact.


Interest in new A-APMs is high, and CMMI’s forthcoming actions in introducing and scaling these models will be closely watched.

September 14, 2018

MIPS: Proposed Changes in 2019

Comments on the Proposed Rule for the Quality Payment Program (QPP) in 2019 were due earlier this week, with a final rule expected in late fall. In the rule, CMS has laid out a path towards reducing burden and bolstering performance in the MIPS program in 2019. Though 2019 marks the end of the transition years of the QPP,  leniencies remain and CMS continues to make requisite tweaks to the structure of MIPS in reaction to stakeholder concerns.

The sustainability of the MIPS track remains an open question, with roughly 482,000 clinicians excluded or opting-out of the program in 2019. CMS estimates a +2% increase overall in Part B payments given the impact of the negative, positive, and exceptional performance payment adjustments.

July 06, 2018

Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) Demonstration

In the Quality Payment Program Final Rule for 2018, the Centers for Medicare and Medicaid Services (CMS) noted their intent to develop a demonstration of an Advanced Alternative Payment Model (A-APM) that meaningfully includes Medicare Advantage. While the MAQI demonstration is still in the proposal stages, the program is indicative of how CMS may move forward with incentivizing greater participation in Medicare Advantage through the Quality Payment Program. The demonstration would allow clinicians to directly count Medicare Advantage patients and/or payments to meet A-APM participation thresholds, without having to participate in a Medicare A-APM. While CMS will require entities to submit data on their Medicare Advantage payment arrangements, the exemption from MIPS and potential to earn the 5% A-APM bonus will likely incentivize participation. While the impact of additional exemptions from the MIPS track is concerning for existing participants, those with significant MA participation will likely benefit from the MAQI option. Additional details about the model are forthcoming, and could make an appearance in this year’s Physician Fee Schedule Rule.

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