Georgia Medicare Qualifying APM Participant QP Status Guide 2026

By Brevy Care Team

Qualifying APM Participant (QP) status is the Medicare Quality Payment Program designation that distinguishes clinicians delivering Medicare Part B care through Advanced Alternative Payment Models from clinicians reporting MIPS. For Atlanta cardiologists practicing through Emory's MSSP ENHANCED ACO, for Marietta primary care physicians participating in Aledade's MSSP BASIC Level E ACO, for Macon orthopedic surgeons in Northside's ACO REACH Global track, QP status is the consequential threshold: cross it, and the clinician is exempt from MIPS entirely, no longer subject to the four-category Quality/Cost/PI/IA reporting machinery, no longer subject to the ±9% MIPS payment adjustment — and instead receives either the legacy 5% APM Incentive Payment (Performance Years 2017-2022), the reduced 3.5% APM Incentive Payment (PY 2023), or — beginning Payment Year 2026 (PY 2024 QP determination) — the structural Qualifying APM Conversion Factor differential applied to the Medicare Physician Fee Schedule itself.

The statutory foundation: Section 1833(z)

QP status exists under Section 1833(z) of the Social Security Act (42 U.S.C. § 1395l(z)), added by Title I, Section 101 of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA, Public Law 114-10, April 16, 2015). Section 1833(z) is the statutory partner to Section 1848(q) (MIPS): together they form the two tracks of the Quality Payment Program established by MACRA.

The statutory framework includes:

• Section 1833(z)(1) — defines QP status and the APM Incentive Payment
• Section 1833(z)(2) — defines QP thresholds (Medicare-only and All-Payer Combination)
• Section 1833(z)(3) — defines Advanced APMs
• Section 1848(q)(1)(C)(ii) — MIPS exclusion for QPs

CMS implementing regulations live at 42 CFR Part 414, Subpart O, with the QP determination and Advanced APM criteria addressed in §§ 414.1305-1465.

The Consolidated Appropriations Act of 2023 (Public Law 117-328, December 29, 2022) subsequently extended the APM Incentive Payment through Performance Year 2023 at a reduced 3.5% rate, after the original 5% rate expired with PY 2022.

What QP status means in practical terms

A clinician who is determined to be a Qualifying APM Participant:

1. Is exempt from MIPS — No Quality, Cost, Promoting Interoperability, or Improvement Activities submission required. No Final Score. No ±9% MIPS adjustment.

2. Receives the APM Incentive Payment (historical) or Qualifying APM Conversion Factor differential (current):

   • PY 2017-2022 (Payment Years 2019-2024): 5% APM Incentive Payment on the prior year's Part B Professional Services aggregate
   • PY 2023 (Payment Year 2025): 3.5% APM Incentive Payment (CAA 2023 extension)
   • PY 2024+ (Payment Year 2026+): Qualifying APM Conversion Factor differential — a higher MPFS Conversion Factor structurally applied to QP clinicians' Part B payments

3. Participates in their Advanced APM with the model's specific quality, cost, and operational requirements (separate from MIPS reporting)

4. Receives QP status determination from CMS via three annual snapshots, with the highest snapshot result used

A clinician achieving Partial QP status (lower thresholds):

• Is MIPS-exempt at election — May elect to participate in MIPS or to be excluded from MIPS without an APM Incentive Payment
• Does not receive the APM Incentive Payment (or CF differential)

QP thresholds — Medicare option

Under the Medicare option (Section 1833(z)(2)(A)), QP thresholds are met by aggregating Medicare Part B Professional Services payments and unique Medicare beneficiaries furnished through Advanced APM Entities. Two threshold tests apply, and meeting either test suffices to qualify as QP.

Payment-amount threshold

The percentage of an eligible clinician's Part B Professional Services payments furnished through Advanced APM(s):

The thresholds increased substantially for PY 2024 per MACRA's statutory schedule. The 75% payment-amount threshold means that at least 75% of the eligible clinician's Medicare Part B Professional Services payments must flow through an Advanced APM Entity.

Patient-count threshold

The percentage of an eligible clinician's unique Medicare patients receiving Part B services through Advanced APM(s):

Meeting either threshold

A clinician achieving the higher of either the payment-amount OR patient-count threshold qualifies as QP. The lower (Partial QP) thresholds operate the same way — meeting either Partial QP threshold qualifies as Partial QP.

Status hierarchy:

• QP (meets QP threshold): MIPS-exempt + APM Incentive Payment/CF differential
• Partial QP (meets Partial QP threshold but not QP): MIPS-exempt at election, no IP
• Neither: MIPS-eligible (subject to MIPS reporting and adjustment)

All-Payer Combination Option

Beginning Performance Year 2019 (Payment Year 2021), Section 1833(z)(2)(C) authorizes the All-Payer Combination Option. Under this option, clinicians may combine Medicare Part B Advanced APM participation with participation in Other Payer Advanced APMs (state Medicaid APMs, Medicare Advantage APMs, commercial payer APMs) to meet QP thresholds.

To use the All-Payer Combination:

1. Clinician must first meet a minimum Medicare-only threshold (lower than the standard Medicare-only QP threshold)
2. CMS then applies the All-Payer thresholds (higher than Medicare-only thresholds) to the combined Medicare + Other Payer participation

The Other Payer Advanced APM must be approved by CMS through the Other Payer Advanced APM Determination process, requiring:

• Use of CEHRT (or alternative quality measurement)
• Payment based on quality measures comparable to MIPS
• More-than-nominal financial risk

The All-Payer Combination is particularly relevant for Georgia clinicians with substantial Georgia Medicaid managed care APM participation, Medicare Advantage APM exposure, or commercial value-based contracts.

QP determination snapshots

CMS conducts three QP determination snapshots each Performance Year:

1. Snapshot 1: January 1 – March 31
2. Snapshot 2: April 1 – June 30
3. Snapshot 3: July 1 – August 31

Each snapshot uses Part B Professional Services claims data for the snapshot period to calculate threshold scores. The highest snapshot drives the QP determination — a clinician achieving QP status in any snapshot is treated as QP for the Performance Year. Conversely, a clinician failing all three snapshots is treated as MIPS-eligible (unless otherwise excluded).

This snapshot-based approach means:

• Early-year QP attainment provides early certainty
• Late-year improvement in Advanced APM participation can rescue QP status
• Clinicians dropping below threshold mid-year may still retain QP status from earlier snapshots
• CMS publishes preliminary QP results after each snapshot via qpp.cms.gov

QP determination levels

CMS determines QP status at three potential levels:

APM Entity-level determination

• All eligible clinicians on the APM Entity participation list receive the same QP determination
• Most common determination level for ACOs (MSSP, ACO REACH)
• Aggregates all APM Entity members' Part B participation

TIN-level determination

• All eligible clinicians billing under the TIN receive the same determination
• Used when APM Entity participation includes a TIN
• Applies to clinicians billing under the participating TIN even if not on the APM Entity list

Individual-level determination

• Specific NPI determination
• Used when other levels don't produce QP status
• Captures individual clinician participation across multiple APM Entities

CMS uses the highest level producing QP status. If APM Entity-level produces QP for an APM Entity, all clinicians on the entity list are QPs. If APM Entity-level fails but TIN-level produces QP, all clinicians on the TIN are QPs. And so on.

Advanced APM criteria

Section 1833(z)(3)(D) defines Advanced APM criteria. An APM qualifies as an Advanced APM if it meets all three:

1. Certified EHR Technology (CEHRT) use

• APM requires participants to use CEHRT meeting ONC certification criteria
• Generally aligned with MIPS Promoting Interoperability requirements

2. Payment based on quality measures comparable to MIPS Quality

• APM payment must depend on quality measures
• Measures must be evidence-based, reliable, and valid
• Comparable to MIPS Quality measures

3. More-than-nominal financial risk OR Medical Home Model

The APM must either:

• Bear financial risk for monetary losses: APM Entity must bear losses if actual expenditures exceed expected expenditures, with risk meeting CMS's nominal-amount standard, OR
• Be a Medical Home Model: Designated by CMS Innovation Center as Medical Home

For the financial-risk standard, the "more-than-nominal" amount has been calibrated through annual PFS Final Rules.

Current Advanced APMs

CMS publishes the list of Advanced APMs annually. Current Advanced APMs include:

Shared Savings Program (MSSP)

• MSSP BASIC Level C — two-sided risk
• MSSP BASIC Level D — two-sided risk
• MSSP BASIC Level E — two-sided risk
• MSSP ENHANCED Track — highest risk/reward

Note: MSSP BASIC Levels A and B (upside-only) are NOT Advanced APMs because they do not meet the more-than-nominal financial risk standard.

ACO REACH

• Professional Track — partial capitation, modest risk
• Global Track — global capitation, substantial risk

CMS Innovation Center (CMMI) Models

• Primary Care First (PCF) — capitated primary care
• Kidney Care Choices (KCC) — CKD and ESRD value-based
• Making Care Primary (MCP) — primary care transformation (launched 2024)
• BPCI Advanced — Bundled Payments for Care Improvement Advanced
• Various other CMMI models with two-sided risk

Episode-based / specialty

• Selected oncology and specialty bundles meeting Advanced APM criteria
• Annual list published by CMS

Models that are NOT Advanced APMs

The following are MIPS APMs but not Advanced APMs (their participants are MIPS-eligible, not QP-eligible):

• MSSP BASIC Level A — upside-only
• MSSP BASIC Level B — upside-only
• Some CMMI models with upside-only or otherwise insufficient risk

MIPS APM participants can use the APM Performance Pathway (APP) as a streamlined MIPS reporting alternative.

The APM Incentive Payment

Through PY 2022, QP status qualified the clinician for the 5% APM Incentive Payment under Section 1833(z)(1)(A). The IP was calculated as:

• 5% of the clinician's prior year (Payment Year - 1) estimated aggregate payments for Part B Professional Services under MPFS
• Paid as a lump sum during the Payment Year
• Not multiplicative on individual claims
• Calculated based on a 12-month look-back period

Example timing: A clinician who was QP for Performance Year 2020 received the 5% APM Incentive Payment in Payment Year 2022 (PY+2 offset), calculated on PY 2021 Part B Professional Services aggregate payments. CMS used administrative data to calculate the IP and paid via lump sum.

CAA 2023 extension

The Consolidated Appropriations Act of 2023 (Public Law 117-328, December 29, 2022) extended the APM Incentive Payment through Performance Year 2023 at a reduced 3.5% rate. The IP was paid in Payment Year 2025 at 3.5% of PY 2024 Part B Professional Services aggregate.

End of APM Incentive Payment

Performance Year 2024 (Payment Year 2026) marks the end of the APM Incentive Payment as a separate payment. Beginning PY 2024, QP status instead drives the Qualifying APM Conversion Factor differential.

Qualifying APM Conversion Factor differential

Beginning Payment Year 2026 (Performance Year 2024 QP determination), CMS publishes two Medicare Physician Fee Schedule Conversion Factors:

1. Standard Conversion Factor — applied to all non-QP Medicare Part B claims
2. Qualifying APM Conversion Factor — applied to QP clinicians' Medicare Part B claims

The Qualifying APM CF is structurally higher than the Standard CF, creating a differential MPFS payment. The exact differential is set via annual PFS Final Rule, generally consistent with the MACRA statutory framework.

This change has several practical implications:

• QPs no longer receive a separate IP lump sum
• Instead, QPs receive higher MPFS payments on every Part B claim during the Payment Year
• The differential is built into the MPFS payment formula itself
• Operationally simpler than lump-sum IP calculation
• Affects Medicare Part B coinsurance calculation (slightly higher beneficiary 20% portion)
• Cumulative annual benefit similar to historical 5% IP, depending on calibration

Performance Year to Payment Year offset (PY+2)

The QP determination cycle uses a two-year offset:

• Performance Year n → QP determination data collection
• Payment Year n+2 → Payment consequence (IP or CF differential)

Examples:

• PY 2022 QP status → PY 2024 5% APM IP
• PY 2023 QP status → PY 2025 3.5% APM IP
• PY 2024 QP status → PY 2026 Qualifying APM CF differential
• PY 2025 QP status → PY 2027 Qualifying APM CF differential

The two-year offset reflects:

• CMS data processing and Snapshot calculation timing
• Annual PFS Final Rule cycle
• Claims processing infrastructure

Annual CMS QP notifications

CMS publishes preliminary QP results via the qpp.cms.gov participation status lookup tool after each snapshot:

• Spring (after Snapshot 1): Preliminary status based on Q1 data
• Summer (after Snapshot 2): Updated status incorporating Q2 data
• Fall (after Snapshot 3): Final status incorporating January-August data

Clinicians and APM Entities can verify status at qpp.cms.gov by NPI or TIN. The lookup tool also shows:

• MIPS eligibility status
• Special status determinations (small practice, rural, HPSA, etc.)
• APM Entity affiliation
• Available reporting options

Georgia provider implications

Wellstar Health System

Wellstar participates in MSSP. Whether Wellstar clinicians achieve QP status depends on which MSSP track Wellstar's ACO operates under (BASIC C/D/E or ENHANCED qualify as Advanced APMs; BASIC A/B do not). Wellstar's ACO REACH participation (if applicable) also drives QP status for participating clinicians.

Emory Healthcare Network

Emory's Clinically Integrated Network ACO participates in MSSP ENHANCED — an Advanced APM. Emory clinicians on the ACO participation list typically achieve APM Entity-level QP status (subject to threshold testing).

Piedmont QCN ACO

Piedmont Quality Care Network participates in MSSP. The specific BASIC level or ENHANCED participation determines whether Piedmont clinicians achieve QP status.

Northside Hospital System

Northside participates in both MSSP and ACO REACH. ACO REACH Professional and Global tracks are both Advanced APMs. MSSP participation depends on the BASIC level or ENHANCED.

Aledade Georgia ACOs

Aledade operates multiple Georgia MSSP ACOs across BASIC Levels A through E and ENHANCED. Aledade's MSSP BASIC E and ENHANCED ACOs qualify as Advanced APMs and produce QP status for participating clinicians meeting thresholds. Aledade's BASIC A/B ACOs are MIPS APMs but not Advanced APMs.

Privia Medical Group Georgia

Privia operates ACO infrastructure across Georgia, including MSSP participation. The track level determines Advanced APM status.

Georgia FQHC ACO networks

Georgia FQHCs participating in MSSP (often via ACO-as-a-Service networks) may achieve QP status. FQHC PPS services aren't subject to MIPS in any case, but QP status determines the Part B Professional Services treatment.

Palmetto GBA Part A/B MAC Jurisdiction J

Palmetto GBA processes Georgia Medicare Part B claims and applies the Qualifying APM CF (vs. Standard CF) per QP determination. Palmetto GBA: 1-866-238-9650.

Worked examples

Example 1: Fulton 70 — Emory PCP achieves QP via MSSP ENHANCED

Dr. Patel, age 70, internal medicine at Emory Decatur. Emory CIN ACO participates in MSSP ENHANCED (Advanced APM). PY 2024:

• Emory CIN ACO snapshot data: Dr. Patel's Part B Professional Services 85% through MSSP ENHANCED Advanced APM
• PY 2024 QP payment-amount threshold: 75% — Dr. Patel exceeds at 85%
• QP status determined at APM Entity level: All Emory CIN ACO eligible clinicians QP
• MIPS-exempt for PY 2024
• PY 2026: Qualifying APM Conversion Factor differential applied to all Dr. Patel's Medicare Part B claims

Example 2: DeKalb 75 — cardiologist Partial QP elects MIPS

Dr. Hoang, age 75, interventional cardiology at Emory Saint Joseph's. Emory CIN ACO participates in MSSP ENHANCED, but Dr. Hoang's Part B Professional Services only 60% through the ACO (much of his catheter lab procedural revenue is outside the ACO attribution). PY 2024:

• Payment-amount threshold for QP 75% — not met (Dr. Hoang at 60%)
• Payment-amount threshold for Partial QP 50% — met (60% > 50%)
• Partial QP status determined
• Dr. Hoang elects to participate in MIPS (not MIPS-exempt without IP)
• Reports MIPS via Heart Disease MVP under Emory Subgroup
• Subject to ±9% MIPS adjustment

Example 3: Cobb 68 — Aledade ACO QP

Dr. Williams, age 68, leads a three-physician family medicine group in Marietta. Practice participates in Aledade Georgia MSSP BASIC Level E ACO (Advanced APM). PY 2024:

• Practice Part B Professional Services 90% through Aledade BASIC E
• Patient-count threshold: 55% of unique Medicare patients through Aledade BASIC E
• Payment-amount 90% > 75% QP threshold — QP achieved
• Patient-count 55% > 50% QP threshold — QP also confirmed
• MIPS-exempt for PY 2024
• PY 2026: Qualifying APM CF differential applied to all practice Medicare Part B claims

Example 4: Worth County 72 — rural FQHC QP via Aledade

Albany Area Primary Health Care FQHC participates in Aledade Georgia MSSP BASIC E ACO. Dr. Johnson, age 72:

• FQHC PPS-paid services NOT subject to MIPS in any case
• Part B Professional Services (chronic care management) 95% through Aledade BASIC E
• QP threshold 75% — exceeded
• QP status — APM Entity-level
• For Dr. Johnson's Part B-billed services: MIPS-exempt + Qualifying APM CF differential PY 2026
• FQHC PPS services unaffected (always not MIPS-subject)

Example 5: Bibb 80 — Northside ACO REACH QP

Dr. Chen, age 80, orthopedic surgeon at Northside Hospital Atlanta. Northside participates in ACO REACH Global Track (Advanced APM). PY 2024:

• Northside ACO REACH Global snapshot: Dr. Chen's Part B Professional Services 78% through ACO REACH
• Payment-amount threshold 75% — exceeded (78%)
• QP status determined
• MIPS-exempt for PY 2024
• PY 2026: Qualifying APM Conversion Factor differential applied

Example 6: Hall 67 — Piedmont QCN Partial QP MIPS reporting

Dr. Singh, age 67, primary care physician affiliated with Piedmont QCN ACO. Piedmont QCN participates in MSSP BASIC Level C (Advanced APM). PY 2024:

• Dr. Singh's Part B Professional Services 55% through Piedmont QCN MSSP BASIC C
• Payment-amount QP threshold 75% — not met
• Payment-amount Partial QP threshold 50% — met
• Partial QP status determined
• Dr. Singh elects to participate in MIPS (not exempt without IP)
• Reports MIPS via APM Performance Pathway (APP) at the APM Entity level via Piedmont QCN
• Subject to ±9% MIPS adjustment via APP scoring

Best practices for Georgia clinicians and APMs

1. Verify Advanced APM status of your APM — Not all APMs are Advanced; confirm BASIC level or specific model qualifies
2. Monitor QP snapshots quarterly — Check qpp.cms.gov participation status after each snapshot release
3. Coordinate with APM Entity on participation list — Ensure NPI is correctly listed; missing list inclusion means missing QP status
4. Understand patient-count vs. payment-amount thresholds — Different services attribute differently; specialty mix matters
5. Plan for All-Payer Combination if applicable — Combine Medicare Advanced APM + state Medicaid APM + commercial APMs for thresholds
6. Document Other Payer Advanced APM approvals — Other Payer Advanced APM Determination required for All-Payer use
7. Time Advanced APM participation changes carefully — Mid-year changes may impact snapshot calculations
8. Plan Partial QP election — Election to participate in MIPS or be exempt without IP is binding for the PY
9. Track APM Entity composition — Affects APM Entity-level QP determination
10. Coordinate with TIN billing — TIN-level QP determination depends on TIN claims attribution
11. Engage with QPP Service Center — 1-866-288-8292 for QP-specific questions
12. Monitor PFS Final Rules — Annual Qualifying APM CF differential calibration
13. Document QP determination for cash flow forecasting — Higher MPFS payment expected during applicable Payment Year
14. Educate clinicians on QP/MIPS distinction — Operational mindset shift from MIPS reporting to APM participation

Common QP issues for Georgia clinicians

1. Misunderstanding which MSSP BASIC levels qualify — Only C/D/E qualify; A/B do not
2. Missing APM Entity participation list — NPI omitted from list means missing QP determination
3. Mid-year APM Entity changes — Joining mid-year may not provide enough snapshot attribution
4. Multiple APM Entity participation — CMS aggregates across APM Entities but TIN-level may conflict
5. Patient-count threshold misunderstanding — Unique patients (not visit count) drive patient-count threshold
6. Payment-amount calculation confusion — Aggregate Part B Professional Services payments, not total Medicare payments
7. Missing Snapshot deadlines — APM Entity must submit accurate participation lists for each snapshot
8. CAA 2023 IP rate confusion — 3.5% applies only to PY 2023; 5% applies PY 2017-2022; CF differential applies PY 2024+
9. Partial QP election timing — Election deadline preceded by CMS notification; missing election can result in default treatment
10. All-Payer Combination misuse — Requires CMS Other Payer Advanced APM Determination first
11. Assuming QP determination automatically continues year-to-year — Re-determined annually
12. Confusing QP and MIPS APM — MSSP BASIC A/B participants are MIPS APMs, not Advanced APM/QP
13. Misunderstanding APP vs. QP — APP is MIPS reporting path for MIPS APMs; QP exempts from MIPS entirely
14. Forgetting Qualifying APM CF affects beneficiary coinsurance — Slightly higher Part B coinsurance for QP claims

Frequently Asked Questions

1. What is a Qualifying APM Participant (QP)? A clinician determined by CMS to be exempt from MIPS and qualified for the APM Incentive Payment (or Qualifying APM Conversion Factor differential starting Payment Year 2026) based on meeting threshold levels of Medicare Part B Professional Services through an Advanced APM Entity. Established by Section 1833(z) of the Social Security Act per MACRA 2015 (Public Law 114-10).

2. What are the QP thresholds for Performance Year 2024? Payment-amount threshold: 75% of Part B Professional Services through Advanced APM(s). Patient-count threshold: 50% of unique Medicare patients through Advanced APM(s). Meeting either threshold suffices.

3. What are Partial QP thresholds for Performance Year 2024? Payment-amount 50% or patient-count 35%. Partial QPs may elect to participate in MIPS or be MIPS-exempt without an APM Incentive Payment.

4. What is the APM Incentive Payment? 5% of the prior-year aggregate Medicare Part B Professional Services payments (PY 2017-2022). Reduced to 3.5% for PY 2023 per CAA 2023 (Public Law 117-328). Replaced beginning PY 2024 by the Qualifying APM Conversion Factor differential.

5. What is the Qualifying APM Conversion Factor differential? Beginning Payment Year 2026 (PY 2024 QP determination), CMS publishes a higher MPFS Conversion Factor for QP clinicians' Part B claims, structurally embedded in the MPFS formula instead of paid as a separate lump-sum IP.

6. Which models are currently Advanced APMs? MSSP BASIC Levels C, D, E; MSSP ENHANCED Track; ACO REACH Professional and Global; Primary Care First; Kidney Care Choices; Making Care Primary; BPCI Advanced; and various CMMI models with two-sided risk. CMS publishes the annual list.

7. Which models are NOT Advanced APMs? MSSP BASIC Levels A and B (upside-only) and certain CMMI models without sufficient risk. These are MIPS APMs but not Advanced APMs.

8. What are the Advanced APM criteria? Per Section 1833(z)(3)(D): (1) Use of Certified EHR Technology; (2) Payment based on quality measures comparable to MIPS; (3) Bear more-than-nominal financial risk OR be a Medical Home Model.

9. How many QP determination snapshots are there per year? Three: January 1 – March 31, April 1 – June 30, July 1 – August 31. The highest snapshot result determines QP status.

10. At what level does CMS determine QP status? APM Entity level (most common, especially ACOs), TIN level, or Individual level. CMS uses the highest level producing QP status.

11. What is the All-Payer Combination Option? Beginning PY 2019, clinicians may combine Medicare Advanced APM participation with Other Payer Advanced APMs (state Medicaid APMs, MA APMs, commercial APMs) to meet QP thresholds. Section 1833(z)(2)(C). Requires CMS Other Payer Advanced APM Determination.

12. How does the Performance Year to Payment Year offset work? PY+2. QP status in PY n drives the payment consequence (IP historically, CF differential currently) in PY n+2. PY 2024 QP determination → PY 2026 Qualifying APM CF differential.

13. How can I check my QP status? At qpp.cms.gov participation status lookup. Enter NPI or TIN. Status updates after each snapshot (spring, summer, fall).

14. Can a clinician be Partial QP and not be MIPS-eligible? Yes. Partial QPs may elect to be MIPS-exempt without the APM Incentive Payment. Or Partial QPs may elect to participate in MIPS. Election is binding for the PY.

15. What happens if I'm in an Advanced APM but don't meet QP thresholds? You're a MIPS APM participant and may report MIPS via APP (APM Performance Pathway), a streamlined MIPS reporting option. Subject to ±9% MIPS adjustment.

16. How does QP status interact with the MIPS payment adjustment? QPs are MIPS-exempt — no MIPS adjustment. Partial QPs electing exemption: no MIPS adjustment. Partial QPs electing MIPS or MIPS APM participants: subject to MIPS adjustment.

17. Is MSSP BASIC A or B an Advanced APM? No. BASIC A and B are upside-only and do not meet the more-than-nominal financial risk standard. They are MIPS APMs (using APP) but not Advanced APMs.

18. Does ACO REACH provide QP status? Yes. Both ACO REACH Professional Track and ACO REACH Global Track meet Advanced APM criteria and can produce QP status for participating clinicians meeting thresholds.

19. How are the QP thresholds calculated for PY 2024? Payment-amount: aggregate Part B Professional Services payments through Advanced APM(s) divided by total aggregate Part B Professional Services payments. Patient-count: unique Medicare patients receiving Part B services through Advanced APM(s) divided by total unique Medicare patients. Threshold met if ≥75% (payment) or ≥50% (patient count).

20. What was the 5% APM Incentive Payment? Lump-sum payment to QPs equal to 5% of prior-year Part B Professional Services aggregate payments, paid in the applicable Payment Year. PY 2017-2022 (Payment Years 2019-2024). Reduced to 3.5% for PY 2023 per CAA 2023.

21. What happens to the 5% IP after PY 2023? Replaced by the Qualifying APM Conversion Factor differential beginning Payment Year 2026 (PY 2024 QP determination). Higher CF structurally applied to QP claims instead of separate lump-sum IP.

22. How does QP status affect Wellstar/Emory/Piedmont/Northside clinicians? Depends on which MSSP/ACO REACH track the system participates in. MSSP BASIC C/D/E and ENHANCED qualify; ACO REACH qualifies; BASIC A/B do not. Major Georgia integrated systems pursuing Advanced APM status produce QP-eligible clinician pools.

23. Are FQHC clinicians eligible for QP status? Yes for Part B Professional Services billed by FQHC clinicians. FQHC PPS-paid services remain not subject to MIPS regardless. Many Georgia FQHCs achieve QP status via Aledade or similar Advanced APM participation.

24. Does QP status affect beneficiary Part B coinsurance? Slightly. Higher Qualifying APM CF means slightly higher MPFS allowed amount, which means slightly higher 20% Part B coinsurance. The differential is modest at typical CF calibrations.

25. Where can Georgia clinicians get QP technical assistance? QPP Service Center 1-866-288-8292; APM Entity (your ACO/model administrator); Acentra Health QIO 1-844-455-8708; Medical Association of Georgia; specialty societies.

Resources and Contacts

For QP questions:

• QPP Service Center: 1-866-288-8292 (qpp.cms.gov)
• Medicare: 1-800-MEDICARE (1-800-633-4227)
• Palmetto GBA Part A/B MAC Jurisdiction J: 1-866-238-9650
• Acentra Health QIO (Georgia): 1-844-455-8708
• GeorgiaCares SHIP: 1-866-552-4464
• Medicare Rights Center: 1-800-333-4114
• Atlanta Legal Aid Society: 404-377-0701
• Georgia Legal Services Program: 1-800-498-9469
• 211 Georgia: Dial 211
• Eldercare Locator: 1-800-677-1116
• Social Security Administration: 1-800-772-1213
• Benefits Coordination & Recovery Center (BCRC): 1-855-798-2627
• CMS Innovation Center: innovation.cms.gov
• Medical Association of Georgia (MAG): mag.org
• Georgia Composite Medical Board: 404-656-3913
• HHS OIG Hotline: 1-800-HHS-TIPS

Why QP status matters for Georgia Advanced APM participants

Qualifying APM Participant status sits at the heart of the value-based care transition that MACRA 2015 set in motion. For every Atlanta cardiologist deciding whether to join Emory's MSSP ENHANCED ACO, for every Marietta primary care practice weighing Aledade Georgia MSSP BASIC E participation, for every Macon orthopedic surgeon evaluating Northside's ACO REACH Global track, QP status is the consequential outcome: MIPS exit, structural payment benefit through the Qualifying APM Conversion Factor differential, and operational simplification (no MIPS Quality/Cost/PI/IA reporting). Georgia's major integrated systems — Wellstar, Emory, Piedmont, Northside — and Georgia's ACO-as-a-Service networks — Aledade, Privia, the Georgia FQHC ACO networks — have been building toward QP-eligible Advanced APM participation since QPP launched in 2017. With Performance Year 2024 raising thresholds to 75% payment-amount or 50% patient-count, and with the historic 5% APM Incentive Payment now replaced by the Qualifying APM Conversion Factor differential, QP status is structurally embedded in Medicare Part B payment going forward. For every Georgia clinician in an Advanced APM, understanding the thresholds, the snapshots, the determination levels, the All-Payer Combination Option, the Partial QP election, and the Payment Year n+2 consequence is essential to navigating the value-based care landscape established by Section 1833(z) of the Social Security Act.