Qualifying Participant (QP) Determinations and Alternative Payment Model (APM) Participation Snapshots

Generally, we review APM participation four times for MIPS eligible clinicians and practices that are participate in a MIPS APM each performance year (each review is called a “snapshot”). We specifically review APM participation for eligible clinicians in the first three snapshots for Qualifying APM Participant (QP) determinations, which we update at each of the respective snapshot dates.

We’ll use data from these dates to:

• Determine QP status
• Update APM participation for each APM Entity

Learn more about QP status.

MIPS Eligible Clinicians in MIPS APMs

The same rules for MIPS eligibility apply to APM participants as to other MIPS eligible clinicians.

This means that individual MIPS eligible clinicians who are participants in MIPS APMs may report through the APP at the individual level. Groups and APM Entities may report through the APP on behalf of their MIPS eligible clinicians; however, the final score earned by the group or APM Entity through the APP would be applied only to those MIPS eligible clinicians who appear on a MIPS APM’s Participation List or Affiliated Practitioner List on one or more snapshot dates.

When Can My Eligibility Change?

Your eligibility could change based on a number of factors including things like joining or leaving an APM Entity or if the APM Entity meets or exceeds the QP thresholds.

Learn more about how eligibility can change

Participants New to a MIPS APM after Snapshot 3

A final review of MIPS APM participation data takes place in the last four months of the year, from the end of snapshot 3 until the end of the applicable Performance Year.

If you join a MIPS APM during that period, you:

• Will be considered a participant in the MIPS APM, and
• Will be eligible to report MIPS through the APP

Note: Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program are required to report the APP for purposes of assessing their quality performance for that program. However, MIPS eligible clinicians participating in Shared Savings Program ACOs also have the option of reporting outside the ACO through the APP, a MIPS Value Pathway (advanced registration required), or traditional MIPS for purposes of being scored under MIPS.