List of Advanced APMs and MIPS APMs under MACRA in 2017

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Now that the Quality Payment Program rule has been finalized, the Centers for Medicare & Medicaid Services (CMS) has confirmed which Alternative Payment Models (APMs) will be considered Advanced APMs, and which will make participants eligible for the MIPS APM scoring standard. We have included the full list of APMs below, but first let’s dig into what these designations mean for you.

Quick Look: APMs vs. MIPS APMs vs. Advanced APMs

If you are still learning about the different types of APMs under MACRA, you are not alone. Here is a quick rundown of the requirements and benefits associated with each model. If you are already familiar with these designations, scroll down to see the full list of APMs in each category.

Category Requirements Benefits of participation
Alternative Payment Models (APMs) The base definition of an APM includes:

  • CMS Innovation Center models (under section 1115A, other than a Health Care Innovation Award)
  • The Medicare Shared Savings Program
  • Demonstrations under the Health Care Quality Demonstration Program
  • Demonstrations required by federal law
Eligible clinicians participating in APMs that do not meet the requirements for Advanced APMs or MIPS APMs will earn a minimum score of 50% in the MIPS Improvement Activities performance category. They will not be eligible for an Advanced APM incentive payment.
MIPS APMs In addition to the base requirements of an APM, requirements for MIPS APMs include:

  • APM Entities participate in the APM under an agreement with CMS or by law or regulation.
  • The APM requires that APM Entities include at least one MIPS eligible clinician on a Participation List, which is the list associated with physicians and entities participating in the APM.
  • The APM bases payment on performance (either at the APM Entity or eligible clinician level) on cost/utilization and quality measures.
Eligible clinicians in MIPS APMs will benefit from advantages under the MIPS APM scoring standard, including automatically receiving at least 50% credit in the Improvement Activities performance category and being able to use existing quality measures required by the APM to successfully report for the Quality performance category under MIPS.
Advanced APMs In addition to the base requirements of an APM, requirements for Advanced APMs include:

  • The APM requires participants to use certified EHR technology.
  • The APM bases payment on quality measures comparable to those in the MIPS Quality performance category.
  • The APM either:
    • Requires APM Entities to bear more than nominal financial risk for monetary losses; or
    • Is a Medical Home Model expanded under the authority of the Centers for Medicare and Medicaid Innovation (section 1115A(c) of the Act).
If eligible clinicians participating in Advanced APMs reach the payment or patient thresholds required to be considered a Qualifying Participant, these clinicians will be exempt from MIPS payment adjustments and can qualify for a 5% Medicare Part B incentive payment each year. Otherwise, if eligible clinicians reach the thresholds required to be considered Partial Qualifying Participants, these clinicians will not receive an incentive payment but can elect to participate in or opt out of MIPS.

2017 APM list based on final criteria

The following list includes the Alternative Payment Models that CMS operates and indicates whether the APM qualifies as a MIPS APM and/or Advanced APM:

APM MIPS APM under the APM Scoring Standard? Advanced APM?
 Accountable Health Communities (AHC)
 Bundled Payment for Care Improvement Model 2 (BPCI)
 Bundled Payment for Care Improvement Model 3 (BPCI)
 Bundled Payment for Care Improvement Model 4 (BPCI)
 Comprehensive Care for Joint Replacement (non-CEHRT)
 Comprehensive ESRD Care (CEC) Model (LDO arrangement)
 Comprehensive ESRD Care (CEC) Model (non-LDO two-sided risk arrangement)
 Comprehensive Primary Care Plus (CPC +) Model
 Financial Alignment Initiative
 Frontier Community Health Integration Program (FCHIP)
 Graduate Nurse Education Demonstration
 Health Plan Innovation (HPI) Part D Enhanced Medication Therapy Management Model
 Home Health Value Based Purchasing Model (HH-VBP)
 Independence at Home Demonstration (IAH)
 Intravenous Immune Globulin (IVIG) Demonstration
 Maryland All-Payer Hospital Model (MM)
 Medicare Advantage Value-Based Insurance Design
 Medicare Care Choices Model (MCCM)
 Medicare Shared Savings Program—Track 1 (MSSP)
 Medicare Shared Savings Program—Track 2 (MSSP)
 Medicare Shared Savings Program—Track 3 (MSSP)
 Million Hearts: Cardiovascular Disease Risk Reduction Model (MH CVDRR)
 Next Generation ACO Model
 Oncology Care Model (OCM) (one-sided risk arrangement)
 Oncology Care Model (OCM) (two-sided risk arrangement)
 Prior Authorization: Repetitive Scheduled Non-Emergent Ambulance Transport
 Prior Authorization: Non-Emergent Hyperbaric Oxygen Therapy Model
 Initiative to Reduce Preventable Hospitalization Among Nursing Home Residents: Phase 2
 State Innovation Models—Round 2 (SIM 2)
 Strong Start For Mothers And Newborns
 Transforming Clinical Practice Initiative (TCPI)

Expanding opportunities for Advanced APM participation

CMS has committed to expanding the opportunities for providers to participate in Advanced APMs. Methods for expansion include creating additional models that meet the definition of an Advanced APM and reopening existing models to additional participants. CMS has announced the following:

  • CMS expects to reopen The CPC+ and Next Generation ACO models to new participants for the 2018 performance year.
  • The Oncology Care Model with two-sided risk will now be available in 2017, which will qualify the model as an Advanced APM beginning in the 2017 performance year.
  • CMS may reopening applications for and/or modify the Comprehensive Care for Joint Replacement model to provide a pathway to Advanced APM participation.
  • CMS may open up participation for a new Medicare Shared Savings Program ACO model called Track 1+ that is slated to begin in 2018. This model would incorporate less downside risk than Tracks 2 or 3 of the Shared Savings Program but would carry enough financial risk to be considered an Advanced APM.

Keep your eye out for new announcements and updates which expand opportunities for Advanced APM participation. Stay up to date by signing up for our newsletter.


Further reading:
At long last: The documentation you need for Improvement Activity audits
Quick-Look Comparison: MIPS 2017 vs. 2018 requirements

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