Qualified Participants (QPs)

Clinicians who demonstrate significant participation in advanced alternative payment models in 2017 based on the CMS methodology are “Qualified Participants” (QPs), exempt from reporting under the MIPS. QPs also earn an advanced APM incentive payment, payable in 2019 for clinicians designated as QPs in 2017.

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Partial QPs

Clinicians with significant participation in Medicare advanced APMs just slightly under the thresholds to qualify for an advanced APM incentive payment in 2017 still receive favorable treatment under the Quality Payment Program.

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MIPS APMs

Clinicians who participate in Medicare APMs but do not qualify for exemption from MIPS (for example, because their payment model does not include downside risk, or their advanced APM volume is too low) may still receive favorable treatment under the Quality Payment Program.

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Interested in exploring advanced APMs in future

Though there are limited options for Medicare advanced APM participation in 2017, CMS plans to increase the number of available Medicare advanced APMs in future years. In addition, beginning in 2019, clinicians may earn advanced APM incentives based on participation in advanced APMs across all payers.

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Clinicians who are exempted due to low-Medicare volume

The MACRA provides an exemption for those eligible clinicians that have low volumes of Medicare patients. CMS has the authority to adjust the threshold through rulemaking.

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MIPS Participants

The MIPS is the default payment track under the MACRA. It ties positive and negative payment adjustments to performance on quality, cost, improvement activities and advancing care information (i.e., the meaningful use of EHRs).

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Rural Providers

Rural providers are not explicitly excluded from the reporting requirements and potential payment adjustments under the MIPS. How rural facilities and clinicians are treated under the MIPS depends on the type of facility and how Medicare is billed for professional services.

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