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Dr. Patrick ConwayActing Principal Deputy Administrator, Deputy Administrator for Innovation and Quality, and CMS Chief Medical OfficerCMS
FY 16-17: Agency Priority Goal
Shift Medicare health care payments from volume to value
Priority Goal
Goal Overview
Many health care providers today receive a payment for each individual service, such as a physician visit, surgery, or blood test, regardless of whether these services help or harm the patient. In other words, many providers are paid based on the volume of care, rather than the value of care provided to patients.
To build a health care system that delivers better care, that is smarter about how dollars are spent, and that makes people healthier, the Affordable Care Act (ACA) created a number of new programs and payment models that move the needle toward rewarding value and quality. These models include Accountable Care Organization (ACO) models, medical home models focused on primary care, and new models of bundling payments for episodes of care. In these alternative payment models (APMs), health care providers are accountable for the quality and cost of the care they deliver to patients and have a financial incentive to coordinate care for their patients who are therefore more likely to receive high quality, team-based care.
In 2011, Medicare made almost no payments to providers through alternative payment models, but by the end of 2014 such payments represented approximately 20 percent of Medicare payments. These APMs and payment reforms that increasingly tie Medicare payments to quality and value are currently moving the health care system in the right direction, and increased alignment across payers and providers would be even more beneficial. When health systems, practices, and clinicians encounter new payment strategies for one payer, but not others, the incentives to fundamentally change their system are weak. In the past, there was no common timeline among payers or providers for moving the health care system away from volume based payments. Therefore, for the first time in the history of the program HHS has set an explicit goal for tying Medicare payments to APMs that reward quality and value over volume.
Strategies
To increase the percentage of Medicare FFS payments tied to APMs that promote high-value, effective care between 2016 and 2017, the key strategies include:
- Growing and enhancing the Medicare Shared Savings Program.
The Medicare Shared Savings Program (Shared Savings Program) was established by section 3022 of the ACA. The Shared Savings Program is a key component of the Medicare delivery system reform initiatives included in the ACA and is a new approach to the delivery of health care. Congress created the Shared Savings Program to facilitate coordination and cooperation among providers to improve the quality of care for Medicare FFS beneficiaries and reduce unnecessary costs. Additionally, provider and patient participation in the Shared Savings Program has significantly increased recently, both enhancing the focus on primary care services and providing additional flexibility in the program. Results from the first two years of the program have been extremely promising.
- Continuing to test and expand new payment and service delivery models under Section 1115A.
The CMS Innovation Center was established by section 1115A of the Social Security Act (as added by section 3021 of ACA). Congress created the CMS Innovation Center for the purpose of testing “innovative payment and service delivery models to reduce program expenditures…while preserving or enhancing the quality of care” for those individuals who receive Medicare, Medicaid, or CHIP benefits. In addition to testing new models, section 1115(c) provides the Secretary of the Department of Health and Human Services (HHS) with the authority to expand through rulemaking the duration and scope of a model being tested, including implementation on a nationwide basis, under certain circumstances.
To drive progress, the CMS Innovation Center has been testing alternative payment models intended to create an environment in which hospitals, physicians, and other providers are rewarded for delivering high-quality health care. Some of these alternative payment models are already seeing promising results, including the Pioneer ACO Model, and Bundled Payments for Care Improvement Initiative (BPCI).
Looking forward, a number of new CMS Innovation Center models will significantly increase the amount of FFS payments tied to quality and value through alternative payment models. For example, the Comprehensive ESRD Care Model, which is expected to begin in FY2016, is designed to identify, test, and evaluate new ways to improve care Medicare beneficiaries with end-stage renal disease. To provide higher quality, more coordinated oncology care, the Oncology Care Model is testing a payment model by which practices will enter into payment arrangements that include financial and performance accountability for episodes of care surrounding chemotherapy administration to cancer patients. Building off the success of the Shared Savings Program and Pioneer ACOs, the Next Generation ACO model will test whether strong financial incentives for ACOs, coupled with tools to support better patient engagement and care management, can improve health outcomes and lower expenditures. Next Generation ACO began on July 11, 2016. In addition, the Comprehensive Care for Joint Replacement Model, which started on April 1, 2016, tests bundled payment and quality measurement for an episode of care associated with hip and knee replacements to encourage hospitals, physicians, and post-acute care providers to work together to improve the quality and coordination of care from the initial hospitalization through recovery. In FY2017, CMS will continue to create new models and evaluate results from existing initiatives in order to consider extending of expanding successful models.
- Establish the Health Care Payment Learning and Action Network.
To accelerate the transition to more advanced payment models, the CMS Innovation Center established the Health Care Payment Learning and Action Network (LAN) — a collaboration between HHS, private payers, large employers, providers, consumers, and state and federal partners. Working together, Learning and Action Network partners:
- Serve as a convening body to facilitate joint implementation and expansion of new models of payment and care delivery
- Identify areas of agreement around movement toward alternative payment models and define how best to report on these new payment models
- Collaborate to generate evidence, share approaches, and remove barriers
- Develop common approaches to core issues such as beneficiary attribution, financial models, benchmarking, and risk adjustment
- Create implementation guides for payers and purchasers
Address barriers to health IT adoption and interoperability to promote successful participation in Alternative Payment Models
- Through efforts such as the Transforming Clinical Practice Initiative, CMS will provide targeted technical assistance to support providers and promote their success in meeting the conditions of participation for the new alternative payment model programs.
- ONC will maintain its Health IT Certification Program and collaborate with CMS on certification program policy matters to ensure that APMs can be fully supported by the certification program. In particular:
- ONC and CMS will coordinate program requirements for HHS’ Alternative Payment Model programs through rulemaking, with particular focus on incentivizing interoperability through conditions of participation and the certification of health IT capabilities focused on quality measurement, exchange between providers, patient engagement, care coordination, and population health management.
- ONC will continue to implement the national priorities outlined in the Federal Health IT Strategic Plan and Interoperability Roadmap, including further developing and communicating a set of (1) interoperability principles for the health care industry, and (2) the best available standards for enabling interoperable health information exchange.
- CMS will reinforce critical capabilities for participation in alternative payment models through, for instance, linking participation to the capacity to electronically coordinate care across settings with certified health IT.ONC will continue to coordinate across HHS operating divisions in defining and implementing a national strategy for promoting and ensuring the safety and privacy & security of adopted health IT.
Progress Update
CMS has established a baseline of 22 percent of Medicare FFS payments tied to alternative payment models in CY 2014. On March 3, 2016 CMS announced that it estimates it has already met its initial target for CY 2016 of tying 30 percent of Medicare payment to alternate payment models (http://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2016-Fact-sheets-items/2016-03-03-2.html). Actual 2016 payment amounts cannot be calculated until reconciled claims data are available nine months after the end of the calendar year.
To drive further progress, CMS also announced 121 new participants in Medicare Accountable Care Organization (ACO) initiatives designed to improve the care patients receive in the health care system and lower costs.
With new participants in the Shared Savings Program (SSP), the Next Generation ACO Model, Pioneer ACO Model, and the Comprehensive ESRD Care Model, there are now:
• Nearly 8.9 million beneficiaries served
• A total of 477 ACOs across SSP, Pioneer ACO Model, Next Generation ACO Model, and Comprehensive ESRD Care Model
• 64 ACOs are in a risk-bearing track including SSP, Pioneer ACO Model, Next Generation ACO Model, and the Comprehensive ESRD Care Model.
The Medicare Shared Savings Program was created by Congress to facilitate coordination and cooperation among providers to improve the quality of care for Medicare FFS beneficiaries and reduce unnecessary costs. On January 11, 2016, CMS announced the selection of 100 ACOs and 147 renewing ACOs that are joining or continuing their participation in the Medicare Shared Savings Program for the 2016 performance year, providing Medicare beneficiaries with access to high-quality, coordinated care across the United States. That brought the total of Shared Savings Program ACOs to 434 serving over 7.7 million Medicare fee-for-service beneficiaries.
The Next Generation ACO Model builds upon the experience from the Pioneer ACO Model and the Medicare Shared Savings Program to offer a new opportunity in accountable care that sets predictable financial targets, enables providers and beneficiaries greater opportunities to coordinate care, and aims to attain the highest quality standards of care. On January 11, 2016, CMS announced that 21 ACOs are participating in the Next Generation ACO model, currently there are 18 active ACOs participating in the model.
The Comprehensive ESRD Care (CEC) Model is designed to identify, test, and evaluate new ways to improve care for Medicare beneficiaries with End-Stage Renal Disease (ESRD). Through the CEC model, CMS will partner with health care providers and suppliers to test the effectiveness of a new payment and service delivery model in providing beneficiaries with patient-centered, high-quality care. CMS announced the applicants who were selected to participate in the model on October 7, 2015.
Additionally, on September 29, 2015, Health and Human Services Secretary Sylvia M. Burwell announced awards to 39 national and regional health care networks and supporting organizations to help equip 140,000 clinicians with the tools and support needed to improve quality of care, increase patient’s access to information, and reduce costs. The Transforming Clinical Practice Initiative is designed to help clinicians achieve large-scale health transformation.
Furthermore, the final rule for Home Health Value Based Purchasing (HHVBP) Model was published on November 5, 2015. On January 1, 2016, CMS began implementing the HHVBP Model among all home health agencies (HHAs) in nine states representing each geographic area in the nation. The HHVBP model is designed to support greater quality and efficiency of care among all Medicare-certified Home Health Agencies (HHA) that provide services in Massachusetts, Maryland, North Carolina, Florida, Washington, Arizona, Iowa, Nebraska, and Tennessee, which will compete on value in the HHVBP model, where payment is tied to quality performance.
This was followed by the Comprehensive Care for Joint Replacement Model (CJR) final rule, which was published on November 24, 2015 and can viewed at the Federal Register. The CJR model tests bundled payment and quality measurement for an episode of care associated with hip and knee replacements to encourage hospitals, physicians, and post-acute care providers to work together to improve the quality and coordination of care from the initial hospitalization through recovery. The model began on April 1, 2016 in hospitals located in 67 selected metropolitan statistical areas (MSAs).
On July 1, 2016 nearly 200 physician group practices and 16 insurance companies began participating in the Oncology Care Model (OCM). OCM incorporates a two-part payment system for participating practices, creating incentives to improve quality of care and furnish enhanced services for beneficiaries who undergo chemotherapy treatment for cancer diagnosis. The two forms of payment include a per-beneficiary Monthly Enhanced Oncology Services (MEOS) payment for the duration of the episode and the potential for a performance-based payment for episodes of chemotherapy care. The MEOS payment assists participating practices in effectively managing and coordinating for oncology patients during episodes of care, while the potential for performance-based payment incentivizes practices to lower the total cost of care and improve care for beneficiaries during treatment episodes. Please see: https://innovation.cms.gov/initiatives/oncology-care/
Under the Medicare Access and CHIP Reauthorization Act (MACRA), CMS and the Office of the National Coordinator for Health Information Technology (ONC) collaborated to release a final rule on October 14, 2016 titled "Medicare Program: Merit-Based Incentive Payment System (MIPS) and Alternative Payment System (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models." This rule created the Quality Payment Program and has finalized policies and processes that will augment momentum for delivery system reform goals. To accompany the new MIPS and APM incentive programs, CMS is developing a new clinician portal for 2017 (qpp.cms.gov) to seamlessly integrate the different functions under MIPS and to enable clinicians to see their APM participation and progress toward the incentive payments.
Additionally, MACRA created the Physician-Focused Payment Model Technical Advisory Committee (PTAC) that will provide recommendations to the Secretary on proposals for new physician-focused payment models submitted by stakeholders. CMS will continue to add functionality to the portal with a goal towards seamlessly integrating the different functions under MIPS and to enable providers to see their APM participation and progress toward the incentive payments.
Through the Quality Payment Program, from 2019 through 2024, clinicians whom CMS designates as Qualifying APM Participants (QPs) by participating in Advanced Alternative Payment Models (Advanced APMs) as defined under the Quality Payment Program rules will be exempt from the payment adjustments under MIPS, and instead will receive a lump sum incentive payment equal to 5 percent of Medicare Part B payments for covered professional services furnished during the prior year. Beginning in 2026, QPs will receive an annual payment update of 0.75 percent compared to 0.25 percent for those who are not QPs. While these incentives do not go into effect until 2019, the adjustments will be based on performance in earlier years. CMS thus expects clinicians to be intensely interested in pathways that allow them to participate in Advanced APMs before 2019, and many clinicians understand that to do so successfully, they should begin building their capabilities as soon as possible.
Moreover, clinicians must have enough of their payments or see enough of their patients through Advanced APMs in order to become QPs, which we expect will motivate them to select APMs that involve the greatest possible percentage of their patients and payments. Beginning for incentive payments in 2021, this threshold can be met through a combination of Medicare payments and payment from other payers, such as Medicaid and private payers. Finally, MIPS eligible clinicians receive a minimum score of one-half of the highest potential score for the improvement activities performance category for APM participation.
HHS and partners continue to provide assistance to health care providers and health IT developers with meeting technology requirements of advanced alternative payment models:
• ONC released online the Health IT Patient Engagement Playbook for Providers. https://www.healthit.gov/playbook/pe/. The tool assists provides with identifying and implementing the most effective uses of health IT for engage engagement. Health IT, particularly certified EHRs, is a requirement and enabling component of data collection, quality measurement, and reporting for most of the CMS alternative payment models.
• ONC published an EHR Model Contract Terms Guide (https://www.healthit.gov/sites/default/files/EHR_Contracts_Untangled.pdf), which explains important concepts in EHR contracts and includes example contract language to help providers and health administrators in planning to acquire an EHR system and negotiating contract terms with vendors.
• ONC released the Draft 2017 Interoperability Standards Advisory (https://www.healthit.gov/standards-advisory/draft-2017) which continues ONC’s commitment to providing actionable and distilled information to health IT developers so they can easily find and re-use the most consensus standards for digitizing health information.
• ONC continued research activities related to MACRA section 106(b)(1), which requires the development of estimates of nationwide health information interoperability as enabled by certified health IT adopters. (https://www.healthit.gov/buzz-blog/electronic-health-and-medical-records/interoperability-electronic-health-and-medical-records/measuring-interoperability-listening-learning/)
To accelerate the transition to more advanced payment models, the CMS Innovation Center established the Health Care Payment Learning and Action Network (LAN). Accomplishments to date include:
• The LAN is in process of standing up several new efforts. The LAN is establishing a new Primary Care Work Group tasked with developing recommendations and supports for transitioning primary care to Alternative Payment Models (APMs).
• The LAN is also a partner in a new Evaluation Hub that is open for evaluation opportunities, with the goal of generating evidence to support successful payment reform.
• A third new initiative is an Implementation Collaborative that will provide practical content to support the implementation of LAN recommendations and alignment of multiple payers in specific regions and states.
• Additionally, the LAN continues to produce work products from its various work groups in addition to the release of the Alternative Payment Model (APM) Framework White Paper, and has recently released the following white papers and reports on:
o White Paper on Lower Extremity Joint Replacement, Cardiac, and Maternity Care-focused Clinical Episode Payment (CEP) Models
o Framework for addressing consumer priorities in value-based care that systems can use to promote dialogued action
o White Paper on Financial Benchmarking for PBP Models
o White Paper on Effective Joint Replacement for Clinical Episode Payment (CEP) Models
o White Paper on Performance Measurement for PBP Models
o White Paper on Maternity Care for CEP Models
o White Paper draft on Cardiac Care for CEP Models
o White Paper on Data Sharing for PBP Models
Next Steps
We will continue to use a combination of strategies to increase the percentage of Medicare FFS payments tied to quality and value through alternative payment models.
On October 25, 2016 CMS announced that it expects to re-open applications for new practices and payers in the Comprehensive Primary Care Plus (CPC+) model and new participants in the Next Generation Accountable Care Organization (ACO) model for the 2018 performance year. In addition, CMS announced that the participants in the Oncology Care Model can switch to two-sided risk in 2017. This adjustment will enable the model participants who choose the two-sided risk track of the model to participate in an Advanced APM beginning in the 2017 performance year.
Under the Quality Payment Program, clinicians may earn a 5 percent incentive payment in 2019 through sufficient participation in the following Advanced APMs in 2017:
• Comprehensive ESRD Care Model (Large Dialysis Organization (LDO) arrangement)
• Comprehensive ESRD Care Model (non-LDO two-sided risk arrangement)
• CPC+
• Medicare Shared Savings Program ACOs - Track 2
• Medicare Shared Savings Program ACOs - Track 3
• Next Generation ACO Model
• Oncology Care Model (two-sided risk arrangement)
- Comprehensive Care for Joint Replacement Payment Model (Certified Electronic Health Record Technology (CEHRT) track) (proposed policy)
In 2018, CMS anticipates that clinicians may also earn the incentive payment through sufficient participation in the following models:
• ACO Track 1+
• Advancing Care Coordination through Episode Payment Models Track 1 (CEHRT track)
The Comprehensive Primary Care Plus (CPC+) is a national advanced primary care medical home model that aims to strengthen primary care through a regionally-based multi-payer payment reform and care delivery transformation. CPC+ will include two primary care practice tracks with incrementally advanced care delivery requirements and payment options to meet the diverse needs of primary care practices in the United States (U.S.). The multi-payer payment redesign will give practices greater financial resources and flexibility to make appropriate investments to improve the quality and efficiency of care, and reduce unnecessary health care utilization. CMS recently announced on October 25, 2016, that CPC+ will be reopening for new practices and payers for the 2018 performance year. CPC+ is a five-year model with Round 1 expected to begin on January 1, 2017 and Round 2 expected to begin on January 1, 2018.
The Advancing Care Coordination through Episode Payment Models (ACC EPMs) initiative is going through rulemaking, with a proposed start date of July 2017. As proposed, the initiative would consist of three new episode payment models (EPMs), which would test holding participants accountable for the quality and cost of certain cardiac and orthopedic episodes of care. The model would help achieve the goal of higher quality at a lower cost for: acute myocardial infarction (AMI), percutaneous coronary intervention (PCI), coronary artery bypass graft (CABG), and surgical hip/femur fracture treatment (SHFFT) 90-day episodes.
The Vermont All-Payer ACO Model will begin in January 2017. This is a total cost of care (TCOC) alternative payment model (APM) in which all the payers within the entire state of Vermont. Medicare, Medicaid, and commercial payers align on the same payment structure to lead care delivery transformation and improve the health of Vermonters.
ONC will continue to develop consensus measures, monitor, and evaluate the extent of interoperable health information exchange capabilities and activities within the health care providers participating in the Medicare and Medicaid programs, related to MACRA Section 106(b)(1). Interoperable health information exchange across the provider and public payer spectrum is national priority and important facet of enabling patient centric and advanced health care models.
ONC will continue to provide technical assistance to administrators of federal health care programs (e.g., HHS-CMS, Department of Defense (DOD), Veterans Affairs (VA)) to further integrate aspects of the health IT and the EHR certification program into their eligibility and participation criteria. The EHR Certification Program is a federal and industry partnership that enables technical review and assessment of health IT product’s functionalities related to requirements of participation for federal programs.
ONC released national estimates for EHR adoption and interoperable health information exchange capability for hospitals during late summer 2016 and related estimates for office-based providers will be released in the fall. These measurement efforts inform the focus and emphasis of federal policy efforts promoting the development and use of various forms of health IT. For both sets of estimates, results will be presented to the Health IT Federal Advisory Committees and published online. Stay tuned to http://www.healthit.gov/facas/for more detailed information about upcoming federal advisory committee meetings and discussions and http://dashboard.healthit.govfor the latest releases of health IT adoption and use data.
ONC will publish its 6th annual Report to Congress on health IT Adoption & Use during October. The report emphasizes the significant increases in EHR adoption over the last 7 years with a focus on the shift from basic to certified EHR adoption; health information exchange and interoperability.
ONC will publish the ONC Health IT Certification Program: Enhanced Oversight and Accountability final rule. The final rule will focus on: (1) establishing a regulatory process for the direct review of certified health IT by ONC; (2) updating ONC authorization and oversight of accredited testing labs (ONC-ATLs); (3) and making identifiable surveillance results of ONC-Authorized Certification Bodies (ONC-ACBs) available on ONC’s Certified Health IT Products List (CHPL).
Upcoming milestones for the Health Care Payment Learning and Action Network include:
• The LAN National APM Data Collection Effort. The LAN's goal, 50 percent adoption of APMs by 2018 for the entire U.S. health system, is in step with what is called for by the Department of Health and Human Services (HHS). The LAN Payer Collaborative data collection initiative conducted from May 19, 2016 to July 13, 2016, captured the actual health care spending in 2015 and estimates of spending in 2016 from participating respondents to provide an estimate of spending through APMs across commercial, Medicare Advantage, and Medicaid market segments.
• For the 2015 metrics, participating health plans submitted data to the LAN, America’s Health Insurance Plans (AHIP), or the Blue Cross Blue Shield Association (BCBSA) and aggregated results were calculated. The 2015 results represent nearly 200 million Americans and approximately 67% of the covered population in three market segments. The data highlights total health care spending across Category 1 (62%), Category 2 (15%), and Categories 3 and 4 (23% combined). The results highlight how health plans pay providers. Participation in this effort has enabled health plans involved in the study to better align various definitions of payment models, improve their tracking of payments via different payment models, and promote a more consistent approach across public and private sectors.
• For the 2016 estimate, data on contracts in place as of January 1, 2016 was collected from health plans of varying size and geographies representing more than 128 million insured lives, or nearly 44% of the combined Commercial, Medicare Advantage and, Medicaid markets. The data revealed progress toward APM implementation, with responding plans showing nearly 25% of payments are expected to flow through APMs in 2016. The results also highlight that continuing payment innovation is required to transform the health care system to one that ties payment to quality and value.
• The 2016 Fall LAN Summit was held on October 25, 2016. This summit focused on many topics including APM adoption, Primary Care Payment Models, Advanced APMs, Population-Based Payment Models, and Multipayer and All-Payer Models among other many other topics.
• The LAN’s Payer Action Collaborative first in-person kick off meeting took place in McLean, VA on October 26. The LAN’s Multi-Stakeholder Maternity Action Collaborative in-person kick off meeting occurred on December 1.
Expand All
Performance Indicators
Percent of Medicare Fee For Service payments tied to Quality and Value in Alternative Payment Models
Contributing Programs & Other Factors
The Centers for Medicare and Medicaid Services (CMS) have been providing healthcare coverage for 50 years and currently covers over 100 million people through Medicare, Medicaid, the Children’s Health Insurance Program (CHIP), and the Health Insurance Marketplace.
The Office of the National Coordinator for Health Information Technology (ONC) is the principal federal entity charged with coordination of nationwide efforts to implement and use the most advanced health information technology and the electronic exchange of health information to improve health care.
The Assistant Secretary for Planning and Evaluation (ASPE) is the principal advisor to the Secretary of the U.S. Department of Health and Human Services on policy development, and is responsible for major activities in policy coordination, legislation development, strategic planning, policy research, evaluation, and economic analysis.
The Agency for Healthcare Research and Quality's (AHRQ) mission is to produce evidence to make health care safer, higher quality, more accessible, equitable, and affordable, and to work within the U.S. Department of Health and Human Services and with other partners to make sure that the evidence is understood and used.
Increasing participation in alternative payment models within a health care system with FFS incentives is a significant challenge. To reach the goal of tying 40 percent of FFS payments to alternative payment models by 2017, a critical mass of payers and providers must adopt these new value-based payment models. This implies the need to actively engage stakeholders from the healthcare community to inform model design to better fit the needs of beneficiaries, providers, and payers—thereby increasing the uptake of alternative payment models. This is also why the Health Care Payment Learning and Action Network (HCPLAN) was established with the intent to accelerate the transition to more advanced payment models by fostering collaboration between private payers, large employers, providers, consumers, and state and federal partners.
In addition, under the Medicare Access and CHIP Reauthorization Act (MACRA), CMS will promulgate policies and processes that will augment momentum for delivery system reform goals. Starting in 2019, providers whom CMS designates as qualifying participants in eligible APMs as defined by MACRA will be exempt from the payment adjustments under the new Merit-Based Incentive Payment System (MIPS), and instead will receive a lump sum incentive payment. After 2025, qualifying APM participants will receive an annual payment update of 0.75 percent compared to 0.25 percent for those who do not fully qualify. While these incentive payments do not go into effect until 2019, the adjustments will be based on performance in ealier year. CMS thus expects providers to be intensely interested in pathways that allow them to participate in eligible APMs before 2019, and many providers understand that to do so successfully, they should begin building their capabilities as soon as possible. Moreover, providers must meet payment amount or patient thresholds in eligible APMs in order to qualify for APM incentive payments, which we expect will motivate them to select APMs that involve the greatest possible percentage of their patients and payments. Beginning in 2021, these threshold can be met through a combination of Medicare payment and payment from other payers, such as Medicaid and private payers. Finally, MIPS eligible providers receive a minimum score of one-half of the highest potential score for clinical practice improvement activities for APM participation.
No Data Available
