New CMS guidance adds flexibility to ACO REACH Model reporting requirements
Previously, CMS finalized the requirement, beginning in 2025, that all Medicare Shared Savings Program (MSSP) participants, regardless of track or Qualified Advanced APM Participant (QP) status, must begin reporting Merit-based Incentive Payment System (MIPS) Promoting Interoperability (PI) category measures and earn a MIPS PI category score unless they would generally be excluded from reporting this data under MIPS.
In addition, beginning Jan. 1, 2025, CMS also finalized a policy that raised the Advanced APM Certified Electronic Health Record (EHR) Technology (CEHRT) use criterion from 75% to “all” eligible clinicians in an Advanced APM Entity (which includes MSSP ACOs and all Advanced APMs).
As discussed in the AMA’s Medicare Physician Fee Schedule Calendar Year 2024 Proposed Rule comments (PDF), both policies would hinder APM participation and move medicine backwards. Moreover, both policies defy the statutory language of the Medicare Access and CHIP Reauthorization Act of 2015, which expressly exempts QPs from MIPS. Congress established relief from burdensome MIPS requirements as a core incentive to join APMs.
The AMA and other stakeholders voiced strong opposition to the PI CEHRT reporting requirements and asked CMS to reverse CEHRT utilization changes for ACO/APM participants.
As a result of the AMA’s advocacy, CMS issued new guidance for the Accountable Care Organization Realizing Equity, Access, and Community Health (ACO REACH) Model that impacts MIPS PI and reporting requirements beginning in 2025. The new guidance gives Reach ACOs flexibility by applying a 90-day CEHRT use requirement for 2025 as well as MIPS exclusions, including the small practice exception. In 2024, about 25% of MSSP ACOs were REACH ACOs.
The AMA will continue to advocate that CMS apply these flexibilities across all MSSP ACOs beginning next year.
Important Sept. 1 deadline: 2024 payments for alternative payment model (APM) participants
Each year since 2019, hundreds of thousands of physicians have received lump sum bonus payments equal to 5% of their Medicare payment schedule revenues from the previous year due to their participation in Medicare APMs. Earlier this summer, CMS awarded these bonus payments to the vast majority of QPs through their designated billing entity. For about 9,000 QPs, however, CMS did not have up-to-date information about the QPs’ billing entity.
As the 2024 bonus payments are based on APM participation in 2022, physicians may have changed their practice arrangements since that time and CMS did not have the information they need to disburse the funds.
There is a Sept. 1 deadline to provide the updated information to CMS. Physicians who believe they achieved QP status in 2022 but have not yet received their payment should download the “2024 QP Notice for APM Incentive Payment” zip file as soon as possible. They should then review the Excel spreadsheet titled “Public Notice,” and if their name is on this list, complete the very brief form within the PDF file “2024 APM Incentive Payment Notice 2024 Billing Information Collection Form” to provide CMS with the needed information.
