As we outlined in the first entry of MACRA Monday, MACRA is broken down into two programs: APMs (Advanced Alternative Payment Models) and MIPS (Merit-based Incentive Payment System). The question your practice should be asking yourself is whether your practice will be participating in the MIPS or APM program. Practices will participate in one or the other, but not both.
Steve Sisko recently tweeted that CMS estimates only 4% of doctors will participate in MACRA as an APM. Regardless of the exact percentage, it’s clear that the majority of providers will need to worry about MIPS and won’t spend much time looking into the details of the APM program. As such, we’ll spend most of our MACRA Monday time diving into the details of MIPS and not APMs. However, in this post we will highlight what would make you qualify as an APM in case that applies to you.
Here’s CMS’ technical definition of who’s included in an APM:
- CMS Innovation Center model
- MSSP (Medicare Shared Savings Program)
- Demonstration under the Health Care Quality Demonstration Program
- Demonstration Required By Federal Law
In the CMS webinars, they offered this easier to understand list of who’s considered an advanced APM in 2017:
- Shared Savings Program (Tracks 2 and 3)
- Next Generation ACO Model
- Comprehensive ESRD Care (CEC) (large dialysis organization agreement)
- Comprehensive Primary Care Plus (CPC+)
- Oncology Care Model (OCM) (two-sided risk track available in 2018)
Those are the details of who should be watching the APM program because they could be a participant. If you’re not participating in any of these programs, then you’ll not be taking part in the APM program. Next week we’ll dive into more details of other requirements to be what is considered an “Advanced APM”. Plus, we’ll dive into the benefits of participating as an advanced APM.
As I mentioned, we’ll be focusing most of our MACRA Monday series on the MIPS program, but it’s important that all practices spend time understanding the APM program even if you’re not going to be impacted by it in 2017. Why? CMS expects that while most practices will start their MACRA journey in the MIPS program, practices will transition to the APM program over time. How quickly that will happen and the process for switching programs will be interesting to watch. However, that’s why even MIPS participants should be keeping an eye on what’s happening with the APM program. It’s important to see the trends and shifts so your practice is ready.
Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA program.
