Deadline to Provide Billing Info for Advance APM Bonus Approaches

UPDATE 11/20/2020: CMS has extended the deadline to update billing information for APM incentive payments to December 13, 2020. 

Eligible clinicians who CMS has notified as having missing billing information for the payment of the Advanced Alternative Payment Model (APM) bonus for the 2018 performance period have until Friday to submit the data.

CMS announced the November 13 deadline in a payment advisory notice published on the Federal Register in September.

The notice stated that CMS was unable to verify the current Medicare billing information for some qualifying participants when it disbursed the calendar year (CY) 2020 APM Incentive Payments. The agency was, therefore, unable to pay out the 5 percent bonus to the qualifying participants.

Qualifying participants who anticipated receiving the Advanced APM bonus and have not should complete a billing form and/or an electronic funds transfer authorization agreement and submit the information to the Quality Payment Program help desk via email by November 13, 2020.

There are more than 25,600 clinicians who need to complete either one or both of the forms by the deadline, according to a list linked in a letter sent to qualifying participants from CMS.

Failure to submit the required information will result in non-payment for the Advanced APM bonus for participation in the Quality Payment Program in 2018, the agency stated.

However, the Medical Group Management Association (MGMA) recently contended that CMS should not tie provider reimbursement for Advanced APM participation to a deadline.

“[W]e are concerned about the large number of QPs on the unpaid list and that group practices in APMs are unaware that their clinicians may be missing payments,” the group said in a recent letter to CMS Administrator Seema Verma. “For this reason, we urge CMS to avoid implementing a deadline for requesting payments and rescind the current deadline, or alternatively, extend the deadline beyond Nov. 13. CMS should use this extra time to engage in extensive outreach efforts, to include individually contacting group practices with QPs who still have outdated or incomplete billing information using contact information available through enrollment files.”

Many group practice leaders have only recently learned that certain clinicians within their APMs did not receive the APM bonus for 2018 and were listed on the public notice file. Some of the clinicians in question had even received a lump sum payment earlier from CMS that they believed to be the complete APM bonus, MGMA stated.

Additionally, the issue with missing billing information appears to disproportionately impact physician assistants, the group wrote in the letter. These providers also did not change billing Tax Identification Numbers (TINs), which could have resulted in missing updated billing information for other qualifying participants.

“Based on the information made available by CMS so far, it is unclear why physician assistants appear to be disproportionally impacted by this issue. It is also unclear whether there is an identifiable reason for this, or if it is merely a coincidence. We urge CMS to evaluate this matter and share any pertinent findings with stakeholders so that we can offer recommendations to improve the APM payment process in the future,” MGMA said.

The APM bonuses have been helpful for providers investing in value-based care capabilities, according to a recent survey conducted by the National Association of ACOs (NAACOS).

About 84 percent of respondents in accountable care organization (ACO) models that qualified as Advanced APMs, like the Medicare Shared Savings Program and Next Generation ACO Model, said the bonus was “extremely important.”

The survey found that the bonus helped to pay for care coordination or data analytics (58 percent of ACOs) and supported the ACO’s move to a risk-based model (51 percent). About 41 percent of respondents also said they have used the payment to recruit new providers, while 39 percent said they used it to pay physician bonuses.

New threshold for Advanced APM participation could prevent many qualifying participants from earning the bonus in the future, however. CMS is planning to up the threshold levels according to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). 

In 2021, the threshold for becoming a Qualifying APM participant (QP) under the Advanced APM track is slated to increase to 75 percent of a clinician’s Medicare Part B payments.

Many providers have called the new thresholds unrealistic and have urged CMS to use its statutory authority to prevent the increase, especially in light of the COVID-19 pandemic.