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


4. How do I participate in an Advanced APM?

  • Physicians participate in an Advanced APM through an APM Entity. There is flexibility in how an APM Entity could be formed. It could be comprised of:
    • A solo practitioner
    • A group practice of physicians and other eligible clinicians with a single tax identification number (TIN)
    • A combination of physicians and other eligible clinicians from different practices and multiple TINs

    Regardless of its makeup, each APM Entity would have its own TIN for participating in a specific Advanced APM. Participation in an Advanced APM is determined at the APM Entity level. Physicians and other eligible clinicians identified on the APM Entity’s Participation List must collectively meet the QP/PQ thresholds as an APM Entity group for each individual physician to receive credit for participation in an Advanced APM. Additional details on becoming a QP/PQ can be found at here. Use the CMS APM Lookup tool to determine your status.

    CMS uses the following criteria to determine which existing APMs qualify for the Advanced APM pathway under the QPP that would allow physicians participating through an APM Entity to be eligible for the 3.5% incentive payment. Advanced APMs under the QPP must:
    • Be a certain Center for Medicare & Medicaid Innovation Model (CMMI), Shared Savings Program track, or certain federal demonstration program;
    • Require participants to use the 2015 certified electronic health record technology (CEHRT);
    • Base payments for services on quality measures comparable to those in MIPS; and
    • Is either a Medical Home Model expanded under CMMI or requires the APM Entity to bear more than nominal financial risk for losses.

    Note: each APM will have its own participation requirements that specify the level of CEHRT use, risk arrangement under that APM, shared savings/losses under that model, etc. The QPP does not affect or change these arrangements. To learn about specific APM participation requirements, please see the overview resources available on PAI’s Advanced APM Pathway page as well as the CMS Innovation Center website

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