CMS continues push to offer additional Advanced APM options under MACRA

The Centers for Medicare and Medicaid Services (CMS) on Tuesday, October 25, 2016, announced additional options for physicians and other clinicians paid under the Medicare Part B Physician Fee Schedule (PFS) to participate in Advanced Alternative Payment Models (Advanced APMs) in 2017, the first performance year under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). CMS also announced additional options for clinicians to participate in Advanced APMs in 2018.

Under MACRA, Advanced APMs are risk-bearing, coordinated care models that link reimbursement to certain quality and outcomes measures and require the use of certified electronic health record technology (CEHRT).

MACRA Overview

MACRA repealed the Sustainable Growth Rate (SGR) formula for PFS updates and set payment updates for all years in the future. In addition, the law created:

  1. The Advanced APM payment track, through which clinicians can qualify for temporary financial bonuses from 2019 through 2024 and higher PFS payment updates beginning in 2026, if they achieve increasing thresholds for participation in Advanced APMs.
  2. The Merit-based Incentive Payment System (MIPS), which provides performance-based Medicare Part B payment adjustments for certain clinicians who remain more closely tied to the fee-for-service reimbursement system.

Together, CMS refers to the Advanced APM payment track and MIPS as the Quality Payment Program (QPP).

In a final rule with comment period on MIPS and the APM Incentives released on October 14, 2016, CMS provided critical detail on the QPP and locked in January 1, 2017, as the start date for the first performance period. The first payment adjustments under MACRA will take effect in 2019.

Additional Advanced APM opportunities in 2017

In its October 26, 2016, announcement, CMS said that the Oncology Care Model (OCM) two-sided risk model would be available beginning in 2017, rather than 2018. As such, CMS anticipates that the OCM two-sided risk model will be an Advanced APM in 2017.

Reflecting changes to the financial risk standard for Advanced APMs made in the final rule on MIPS and APM Incentives, CMS anticipates that Advanced APMs available in 2017 will be:

  • Comprehensive End-Stage Renal Disease (ESRD) Care Model (large dialysis organization (LDO) arrangement)
  • Comprehensive ESRD Care Model (non-LDO arrangement)
  • Comprehensive Primary Care Plus (CPC+)
  • Medicare Shared Savings Program (MSSP) Accountable Care Organization (ACO) – Track 2
  • MSSP ACO – Track 3
  • Next Generation ACO
  • OCM two-sided risk arrangement

CMS said that it would publish a final list of Advanced APMs for 2017 before January 1, 2017.

Additional Advanced APM opportunities in 2018

CMS also announced that it anticipates reopening Next Generation ACO and CPC+ for new participants in 2018. As Next Generation ACO and CPC+ were originally launched by the Center for Medicare and Medicaid Innovation (CMMI), the two pilots would not have been open for additional applicants in 2018.

Notably for health plans and other health care payers, the anticipated reopening of CPC+ would mean that additional plans and payers also could apply to participate in this multi-payer initiative beginning in 2018.

In addition to the previously listed Advanced APMs that CMS anticipates will be available in 2017, the agency anticipates making available the Advanced APMs listed below in 2018:

  • MSSP ACO Track 1+ (further detail forthcoming in other regulations on the program intended to help MSSP ACO Track 1 participants transition to payment arrangements that include downside financial risk)
  • New Voluntary Bundled Payment Model
  • Comprehensive Care for Joint Replacement (CJR) Model – CEHRT track
  • Advancing Care Coordination Through Episode Payment Models – CEHRT track

For the bundled payment models listed above, CMS has proposed providing a CEHRT track for organizations who certify that clinicians participating in the model use CEHRT, as well as a track for organizations that do not certify CEHRT use. Only the CEHRT track of the bundled payment models is expected to be considered an Advanced APM.

List of Advanced APMs expected to grow

Health care stakeholders will need to monitor these lists over time because CMS expects that additional models will become available as additional models are proposed and developed, including through the Physician-focused Payment Technical Advisory Committee (PTAC) process. MACRA created PTAC to review proposals for new physician-focused payment models (which could be Advanced APMs) and make recommendations to CMS as to whether the proposed models should be piloted.

PTAC on October 1, 2016, began accepting non-binding letters of intent to propose new payment models from health care stakeholders. PTAC expects to begin accepting formal proposals by December 1, 2016, with a goal of facilitating additional Advanced APM options for clinicians for 2018.

For more on MACRA and the timeline for implementation, visit

Anne Phelps
Principal | Deloitte Advisory
US Health Care Regulatory Leader
Deloitte & Touche LLP
Latest conversations from Anne Phelps on Twitter

Daniel Esquibel
Senior Manager
Deloitte & Touche LLP

Heather Hagan
Senior Manager
Deloitte & Touche LLP


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