Medicare QPP

Physicians Advocacy Institute

These resources have not been updated since 2023 but the general details remain relevant. For a summary of the key changes for CY 2024, please click here.

Frequently Asked Questions Updated for 2023


3. If I am in an alternative payment model (such as an ACO), do I still have to participate in MIPS?

  1. If you are participating in an ACO, you will first need to determine if the ACO is a Medicare Shared Savings Program (MSSP) Basic Track or ENHANCED. If you are in Basic Track Levels A-D, you are not considered to be participating in an Advanced APM, but you are considered to be participating in a MIPS APM. To learn more about MIPS APMs, please see PAI’s MIPS APM Overview available on PAI’s QPP Resource Center.

    If you are in a MSSP Basic Level E or the ENHANCED Track, you are considered to be participating in an Advanced APM for QPP purposes. However, to be exempt from MIPS participation, you must be considered a Qualifying Advanced APM Participant (QP). You receive this determination if the ACO you are participating, as a whole, either:
    • Sees 35% of its Medicare Part B patients through the Advanced APM, OR
    • Receives 50% of its Medicare Part B payments through the Advanced APM.

    Even though the determination is made at the ACO level (or the APM Entity level), the determination is applied at the individual level. Use the CMS APM Lookup tool to determine your status.

    To learn more about Advanced APM participation, please see the following resources available on PAI’s Advanced APM Overview Additional resources are also available on CMS’s QPP website and the CMS QPP Resource Library.

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