All-Payer APM Option

Beginning in performance year 2019, the Centers for Medicare & Medicaid Services (CMS) added the “All-Payer Combination Option” for the Advanced Alternative Payment Model (APM) pathway to give clinicians more opportunities to participate in the Quality Payment Program.

The APM track is open to relatively few providers because:

  1. Physicians and other clinicians must participate in a Medicare Advanced APM and;
  2. They must satisfy a sufficient volume requirement. 

The All-Payer Combination Option will allow more clinicians to join the APM track because under the new system, clinicians can either participate in just Medicare Advanced APMs or a combination of Medicare Advanced APMs and other payer advanced APMs to meet the volume requirement. In 2019, CMS allowed both payers and clinicians to initiate a determination on whether a non-Medicare model qualifies as an advanced APM. In 2020, CMS will review the payment arrangement information submitted by each payer to determine whether it meets the Other-Payer Advanced APM criteria. Once reviewed and approved, CMS will post a list of Other-Payer Advanced APMs online before the QP Performance Period.

The Advanced Alternative Payment Model option may be beneficial to groups because that who are determined by CMS to be Qualified APM Participants (QPs) will receive a 5% APM incentive payment in the payment year and will not be subject to the MIPS reporting requirements or payment adjustments.

The Centers for Medicare & Medicaid Services (CMS) have posted several models that are eligible Advanced APMs in 2020. Eligible clinicians and their groups should also check their participation status to see if CMS has determined your APM status.