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The Medicare Quality Payment Program (QPP) is the framework under which Medicare Part B pays virtually all physicians, advanced practice providers (NPs, PAs, CRNAs, CNSs), and certain other clinicians who furnish Medicare-covered services. QPP was established by Title I of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA, Public Law 114-10, signed into law by President Obama on April 16, 2015). QPP became operational on January 1, 2017 with the first Performance Year, and the first Payment Year adjustments based on QPP performance arrived in 2019.

MACRA accomplished two transformative things. First, it permanently repealed the Sustainable Growth Rate (SGR) — a formula that had governed Medicare Part B physician payment updates since 1997 and had threatened catastrophic payment cuts (up to 21%+) almost every year, requiring Congress to pass 17 separate "doc fix" bills between 2003 and 2014 to avert the cuts. The SGR was widely regarded as a failed policy mechanism. MACRA's SGR repeal ended that perennial crisis.

Second, MACRA created the two-track Quality Payment Program:

  • The Merit-Based Incentive Payment System (MIPS) under Section 1848(q) of the Social Security Act — a performance-based payment adjustment system that consolidated three legacy programs (Physician Quality Reporting System, Value-Based Payment Modifier, Medicare EHR Incentive Program/"Meaningful Use") into a single framework with four performance categories
  • The Advanced Alternative Payment Model (Advanced APM) track under Section 1833(z) of the Social Security Act — an exemption-and-incentive track for clinicians participating sufficiently in qualifying value-based care models (such as two-sided MSSP tracks, ACO REACH, Primary Care First, Kidney Care Choices, and others)

For Georgia specifically:

  • Every Medicare Part B clinician in Georgia is subject to QPP — unless exempt through the low-volume threshold or qualifying as an Advanced APM Qualifying APM Participant (QP)
  • Major Georgia integrated systems — Wellstar Health System, Emory Healthcare Network, Piedmont Healthcare, Northside Hospital System, and others — manage QPP performance for thousands of clinicians
  • Independent physician practices and small group practices face significant QPP compliance burdens and may face downward payment adjustments without proper reporting
  • MIPS payment adjustments reach ±9% of Medicare Part B payment beginning Performance Year 2022 (Payment Year 2024) — a substantial financial stake

QPP has evolved substantially since 2017. The Bipartisan Budget Act of 2018 (Public Law 115-123, February 9, 2018) modified the Cost category timing, weighting, and exclusion rules. The Consolidated Appropriations Act of 2023 (Public Law 117-328, December 29, 2022) extended the 5% APM Incentive Payment through Performance Year 2023 (originally scheduled to end at Performance Year 2022). Annual Physician Fee Schedule Final Rules continue to refine performance category weights, performance thresholds, measure sets, and other parameters. The MIPS Value Pathways (MVPs) specialty-specific reporting framework was introduced for Performance Year 2023 as a streamlined alternative to traditional MIPS.

This guide walks Georgia Medicare Part B clinicians, practices, and the beneficiaries who depend on them through the full QPP framework: the statutory authority, the SGR repeal context, the MIPS four-category structure, the Advanced APM qualifying thresholds, the MIPS Value Pathways, the APM Incentive Payment extension, the low-volume threshold exclusion, the connection to MSSP and ACO REACH, and the operational implications for Georgia clinicians and beneficiaries.

Key Takeaways (Callout)

  • QPP is the Medicare Part B physician quality payment framework established by Title I of MACRA 2015 (Public Law 114-10, April 16, 2015), operational since January 1, 2017.
  • MACRA repealed the Sustainable Growth Rate (SGR) — a 1997-2015 payment formula that had threatened annual Medicare Part B cuts.
  • QPP has two tracks: MIPS under Section 1848(q) SSA and the Advanced APM track under Section 1833(z) SSA.
  • MIPS uses four performance categories: Quality, Cost, Promoting Interoperability (formerly Meaningful Use), and Improvement Activities.
  • MIPS produces a Final Score 0-100 that determines payment adjustments — currently up to ±9% of Medicare Part B payment beginning Performance Year 2022 (Payment Year 2024).
  • Performance Year-to-Payment Year offset is PY+2 (Performance Year 2022 → Payment Year 2024).
  • MIPS Value Pathways (MVPs) is a specialty-specific reporting framework introduced for Performance Year 2023 — streamlined alternative to traditional MIPS.
  • Advanced APMs exempt qualifying clinicians (Qualifying APM Participants, or QPs) from MIPS and historically provided a 5% APM Incentive Payment for Performance Years 2017-2022.
  • Consolidated Appropriations Act of 2023 (Public Law 117-328, December 29, 2022) extended the 5% APM Incentive Payment through Performance Year 2023.
  • Beginning Payment Year 2026 (Performance Year 2024), QPs receive a Qualifying APM Conversion Factor differential rather than a separate APM Incentive Payment.
  • Low-volume threshold: clinicians with $90,000 or less in Medicare Part B charges, 200 or fewer Part B patients, or 200 or fewer covered Part B services are exempt from MIPS.
  • Georgia integrated systems (Wellstar, Emory, Piedmont) manage QPP performance for thousands of clinicians; independent practices face heavier compliance burdens.

Statutory Authority and Program History

Sustainable Growth Rate (SGR) Background

From the Balanced Budget Act of 1997 through April 2015, Medicare Part B physician payment updates were governed by the Sustainable Growth Rate (SGR) formula at Section 1848(f) of the Social Security Act. The SGR tied annual Medicare Part B payment updates to growth in gross domestic product (GDP), with a built-in mechanism that demanded payment cuts if cumulative Medicare Part B spending exceeded GDP-tied targets. Because Medicare Part B spending growth consistently outpaced GDP growth, the SGR formula generated annual demands for substantial payment cuts — reaching 21% or more in some years.

Congress passed 17 separate "doc fix" bills between 2003 and 2014 to avert SGR-driven payment cuts. Each year, the underlying cumulative SGR cut grew larger because deferred cuts compounded. By early 2015, the threatened SGR cut was approaching 21.2%, and the unsustainable nature of the perennial doc-fix politics had become broadly recognized as a failed mechanism.

MACRA 2015 SGR Repeal

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA, Public Law 114-10) was signed into law by President Obama on April 16, 2015. Section 101 of MACRA accomplished:

  • Repeal of the SGR
  • Stable Medicare Part B payment updates for the transition period (2015-2019): annual 0.5% increases
  • Two-track Quality Payment Program establishment

QPP Statutory Framework

  • Section 1848(q) SSA — Merit-Based Incentive Payment System (MIPS)
  • Section 1833(z) SSA — Advanced Alternative Payment Models (Advanced APMs)
  • 42 CFR Part 414 Subpart O — QPP implementing regulations
  • Annual Physician Fee Schedule (PFS) Final Rules — performance year parameters

Implementation Timeline

Year Performance Year Payment Year Significance
2017 PY 2017 PY 2019 First QPP Performance Year
2018 PY 2018 PY 2020 BBA 2018 modifications
2019-2021 PY 2019-2021 PY 2021-2023 Performance threshold rises
2022 PY 2022 PY 2024 ±9% maximum adjustment reached
2023 PY 2023 PY 2025 MVPs launched; APM Incentive Payment extended via CAA 2023
2024+ PY 2024+ PY 2026+ Qualifying APM Conversion Factor differential begins

Bipartisan Budget Act of 2018

The Bipartisan Budget Act of 2018 (BBA 2018, Public Law 115-123, February 9, 2018) modified QPP:

  • Allowed CMS to gradually weight the Cost category over multiple years
  • Modified low-volume threshold exclusion rules
  • Permitted virtual group reporting
  • Other technical refinements

Consolidated Appropriations Act of 2023

The Consolidated Appropriations Act of 2023 (CAA 2023, Public Law 117-328, December 29, 2022) included:

  • Extension of the 5% APM Incentive Payment for one additional year, through Performance Year 2023
  • Other Medicare provisions

The CAA 2023 extension was a major policy victory for value-based care advocates who argued the APM Incentive Payment was critical to maintaining Advanced APM participation.

MIPS — Merit-Based Incentive Payment System

Eligible Clinicians

MIPS applies to:

  • Physicians (MD/DO)
  • Physician assistants (PAs)
  • Nurse practitioners (NPs)
  • Clinical nurse specialists (CNSs)
  • Certified registered nurse anesthetists (CRNAs)
  • Physical therapists
  • Occupational therapists
  • Speech-language pathologists
  • Audiologists
  • Clinical psychologists
  • Registered dietitians/nutrition professionals
  • Clinical social workers
  • Certified nurse-midwives

Exemptions

Clinicians are exempt from MIPS if:

  • They are below the low-volume threshold (Medicare Part B charges of $90,000 or less, 200 or fewer Medicare Part B patients, or 200 or fewer covered Part B services in determination period)
  • They are Qualifying APM Participants (QPs) in an Advanced APM
  • They are in their first year of Medicare enrollment as a Part B clinician
  • They are participating in another QPP track exemption

Four Performance Categories

Quality (30% of Final Score for PY 2024)

  • Successor to the Physician Quality Reporting System (PQRS)
  • Report 6 quality measures (5 + 1 outcome measure typically) for at least 12 months
  • 200+ measures available across specialties
  • Scored against benchmarks
  • Reporting options: claims, registry, QCDR, EHR

Cost (30% of Final Score for PY 2024)

  • Successor to the Value-Based Payment Modifier
  • Calculated from claims data — no reporting required
  • Measures include Total Per Capita Cost (TPCC), Medicare Spending per Beneficiary (MSPB), and episode-based measures
  • CMS attributes clinicians to cost measures based on plurality of care

Promoting Interoperability (25% of Final Score for PY 2024)

  • Successor to the Medicare EHR Incentive Program ("Meaningful Use")
  • Use certified EHR technology
  • Measures include e-prescribing, health information exchange, patient electronic access, public health/clinical data exchange

Improvement Activities (15% of Final Score for PY 2024)

  • Activities improving clinical practice or care coordination
  • Categories: expanded practice access, population management, care coordination, beneficiary engagement, patient safety, achieving health equity, etc.
  • Report 2-4 activities depending on practice size and characteristics

Final Score

Each category produces a score 0-100, weighted to produce a Final Score 0-100:

  • Final Score ≥ Performance Threshold → positive payment adjustment
  • Final Score < Performance Threshold → negative payment adjustment
  • Final Score = Performance Threshold → neutral (0% adjustment)

Performance Threshold

  • PY 2017: 3 points
  • PY 2018: 15 points
  • PY 2019: 30 points
  • PY 2020: 45 points
  • PY 2021: 60 points
  • PY 2022, 2023, 2024: 75 points (held flat per BBA 2018 and PFS rules)

Payment Adjustment

Maximum payment adjustment (positive or negative) escalated:

  • PY 2017 (PY 2019): ±4%
  • PY 2018 (PY 2020): ±5%
  • PY 2019 (PY 2021): ±7%
  • PY 2020+ (PY 2022+): ±9%

MIPS is budget-neutral — positive adjustments are funded by negative adjustments, plus an Exceptional Performance Bonus (additional bonus for high performers, funded through PY 2022 by a separate pool). The Exceptional Performance Bonus ended after Performance Year 2022.

Reporting Options for MIPS

  • Individual reporting (single clinician)
  • Group reporting (TIN-level)
  • Virtual Group reporting (BBA 2018 added option)
  • MIPS Value Pathway (MVP) reporting (PY 2023+)
  • APM Performance Pathway (APP) reporting (for ACO participants)
  • Subgroup reporting (PY 2024+ pilot)

MIPS Value Pathways (MVPs)

The MIPS Value Pathways (MVPs) framework launched for Performance Year 2023. MVPs are specialty-specific reporting bundles — clinicians select an MVP appropriate to their specialty and report a streamlined measure set within that MVP rather than choosing from the full MIPS catalog.

MVPs available for PY 2023+ include:

  • Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
  • Advancing Care for Heart Disease
  • Advancing Rheumatology Patient Care
  • Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
  • Improving Care for Lower Extremity Joint Repair
  • Patient Safety and Support of Positive Experiences with Anesthesia
  • Promoting Wellness
  • Supportive Care for Neurodegenerative Conditions
  • Value in Primary Care
  • (Additional MVPs added annually)

MVPs are intended to simplify MIPS reporting and align measures with specialty-specific clinical practice. CMS has signaled MVPs are the future direction for MIPS.

Advanced APM Track

Qualifying APM Participant (QP) Status

The Advanced APM track exempts clinicians from MIPS and historically provided a 5% APM Incentive Payment. To qualify, clinicians must achieve Qualifying APM Participant (QP) status by meeting payment-amount or patient-count thresholds in qualifying Advanced APMs.

QP thresholds (Medicare option):

  • Payment-amount threshold: 75% of Medicare Part B payments through Advanced APM (PY 2024)
  • Patient-count threshold: 50% of Medicare Part B patients through Advanced APM (PY 2024)

Lower thresholds qualify for Partial QP status — exempt from MIPS but no APM Incentive Payment.

What Counts as an Advanced APM

An APM qualifies as Advanced if it:

  • Requires use of certified EHR technology
  • Provides payment based on quality measures comparable to MIPS Quality category
  • Requires participating entities to bear financial risk for monetary losses (or is a Medical Home Model)

Advanced APMs currently include:

  • MSSP BASIC Levels C, D, E (two-sided)
  • MSSP ENHANCED Track
  • ACO REACH (Professional and Global)
  • Primary Care First (PCF)
  • Kidney Care Choices (KCC)
  • Making Care Primary (MCP)
  • Comprehensive ESRD Care (legacy)
  • Bundled Payments for Care Improvement Advanced (BPCI Advanced)
  • Various other CMMI models

Note: MSSP BASIC Levels A and B (upside-only) do NOT qualify as Advanced APMs.

APM Incentive Payment History

  • Performance Years 2017-2022: 5% APM Incentive Payment paid in payment years 2019-2024
  • Performance Year 2023: 3.5% APM Incentive Payment (reduced by Consolidated Appropriations Act of 2023 from the originally scheduled level; CAA 2023 extended the program at this reduced level)
  • Performance Year 2024 and beyond: Qualifying APM Conversion Factor differential replaces the separate incentive payment

Qualifying APM Conversion Factor

Beginning Payment Year 2026 (Performance Year 2024), QPs receive a Qualifying APM Conversion Factor that is higher than the standard Conversion Factor used for non-QPs and MIPS-participating clinicians. This is a structural differential built into the Medicare Physician Fee Schedule formula.

Connection to MSSP and ACO REACH

  • MSSP BASIC Levels C, D, E and ENHANCED Track qualify as Advanced APMs. Clinicians sufficiently participating in these tracks may achieve QP status and exempt themselves from MIPS.
  • ACO REACH (both Professional and Global tracks) qualifies as Advanced APMs. ACO REACH clinicians may achieve QP status.
  • MSSP BASIC Levels A and B (upside-only) do NOT qualify as Advanced APMs — clinicians in these tracks remain subject to MIPS unless otherwise exempt.

For Georgia integrated systems like Wellstar, Emory, and Piedmont running large MSSP ACOs, choosing two-sided risk (BASIC Levels C-E or ENHANCED) is often partly motivated by the Advanced APM qualification for their participating clinicians.

Georgia Provider Implications

Major Georgia Integrated Systems

Wellstar Health System, Emory Healthcare Network, Piedmont Healthcare, Northside Hospital System, and other Georgia integrated systems employ thousands of clinicians subject to QPP. These systems typically:

  • Manage MIPS reporting at the group (TIN) level
  • Invest in EHR and quality reporting infrastructure
  • Coordinate Advanced APM participation through their MSSP or ACO REACH ACOs
  • Provide internal performance dashboards to clinicians

Independent Practices

Independent physician practices in Georgia face heavier QPP compliance burdens:

  • Smaller groups have less infrastructure for quality reporting
  • Solo practitioners may qualify for the low-volume threshold exemption
  • Advanced APM participation through Aledade or other ACO-as-a-Service networks is increasingly common
  • MIPS Value Pathways (MVPs) may simplify reporting for specialists

FQHCs and RHCs

Federally Qualified Health Centers and Rural Health Clinics in Georgia are subject to specific QPP considerations:

  • FQHCs are not subject to MIPS for their core PPS-paid services but may have MIPS-relevant Part B clinicians
  • RHCs have analogous distinctions
  • Several Georgia FQHCs participate in MSSP ACOs and may achieve Advanced APM status

Worked Examples

Example 1: Fulton 70 — PCP MIPS Reporting

A 70-year-old beneficiary's primary care physician practices in a 5-physician independent group in Fulton County (Atlanta). The PCP exceeds the low-volume threshold and is not in an Advanced APM. The PCP reports MIPS at the group (TIN) level: 6 Quality measures, completes Promoting Interoperability requirements with certified EHR, and reports 4 Improvement Activities. The group's Final Score for PY 2024 is 82, exceeding the 75-point Performance Threshold. The group receives a small positive payment adjustment in PY 2026.

Example 2: DeKalb 75 — Cardiologist Advanced APM QP

A 75-year-old beneficiary's cardiologist practices in a Piedmont-affiliated cardiology group that participates in the Piedmont MSSP ACO at the ENHANCED Track (two-sided, Advanced APM-qualifying). The cardiologist receives more than 75% of Medicare Part B payments through the Advanced APM and qualifies as a QP. As a QP, the cardiologist is exempt from MIPS and receives the Qualifying APM Conversion Factor differential.

Example 3: Cobb 68 — Small Practice Low-Volume Exclusion

A 68-year-old beneficiary sees a solo internist in Cobb County. The internist's Medicare Part B charges in the determination period are $75,000 — below the $90,000 low-volume threshold. The internist is exempt from MIPS. No reporting required; no payment adjustment.

Example 4: Worth County 72 — Rural FQHC

A 72-year-old Worth County beneficiary sees an FQHC PCP. The FQHC's PPS-paid services are not subject to MIPS, but the FQHC's Medicare Part B-billed clinicians may be subject to MIPS depending on their individual circumstances. The FQHC participates in an Aledade-affiliated MSSP ACO; Advanced APM status may exempt participating clinicians from MIPS.

Example 5: Bibb 80 — Specialist MVP Reporting

An 80-year-old Bibb County beneficiary sees an orthopedic surgeon for a knee replacement. The orthopedist participates in the "Improving Care for Lower Extremity Joint Repair" MVP — reporting a streamlined specialty-specific measure set within MIPS. The MVP approach simplifies the orthopedist's reporting compared to traditional MIPS measure selection.

Example 6: Hall 67 — ENHANCED ACO Advanced APM

A 67-year-old Hall County beneficiary's PCP participates in an ENHANCED Track MSSP ACO affiliated with Northside Hospital. The PCP receives more than 50% of Medicare Part B patients through the Advanced APM and qualifies as a QP. The PCP is exempt from MIPS, and the ACO is exempt from MIPS reporting requirements for the QP-qualifying participating clinicians.

Best Practices

  1. For all Part B clinicians: confirm your MIPS eligibility annually — low-volume threshold determinations and QP status may change.
  2. Track Quality Payment Program performance feedback at qpp.cms.gov.
  3. For groups: report at the TIN level to consolidate performance management.
  4. For specialists: evaluate MIPS Value Pathways (MVPs) as they expand.
  5. For independent practices: consider ACO participation through Aledade or other ACO-as-a-Service networks to access Advanced APM status.
  6. For ACO participants: confirm Advanced APM track qualification — BASIC Levels A/B do NOT qualify; C/D/E and ENHANCED do.
  7. Track QP status thresholds — payment-amount and patient-count thresholds rise over time.
  8. Use the QPP Service Center (1-866-288-8292) for technical questions about participation, scoring, and payment adjustments.
  9. Implement certified EHR technology to satisfy Promoting Interoperability category requirements.
  10. Choose Improvement Activities aligned with practice priorities — many activities are already in place and just need attestation.
  11. Monitor the annual PFS Final Rule for category weight changes, performance threshold updates, and measure set revisions.
  12. For integrated systems: provide internal performance dashboards to clinicians.
  13. For FQHCs: distinguish PPS-paid services from Part B-billed services for MIPS applicability.
  14. For all stakeholders: plan for the Qualifying APM Conversion Factor differential beginning Payment Year 2026.

Common Issues

  1. MIPS reporting overlooked by small practices, leading to maximum negative payment adjustment (currently ±9%).
  2. Cost category attribution disputes — clinicians may dispute attribution under TPCC, MSPB, or episode-based measures.
  3. Quality measure benchmark complexity — measure benchmarks change annually.
  4. Promoting Interoperability EHR certification gaps — practices may not have certified EHR technology, blocking PI scoring.
  5. Improvement Activities attestation rigor — CMS may audit attestation; documentation important.
  6. Low-volume threshold determination timing — measured in determination periods that may not align with calendar years.
  7. QP threshold misses — clinicians may participate in Advanced APMs but not meet the QP threshold percentages.
  8. Partial QP status confusion — Partial QPs are exempt from MIPS but do not receive APM Incentive Payment.
  9. Hardship exceptions — clinicians can apply for hardship exceptions for natural disasters, EHR issues, etc.
  10. Virtual group complexity — virtual group reporting requires coordination; less common than originally anticipated.
  11. Reweighting in special circumstances — CMS may reweight categories due to public health emergency or other circumstances.
  12. MVP vs. traditional MIPS choice — practices must decide; once chosen, the MVP defines the reporting framework.
  13. APM Performance Pathway (APP) vs. MIPS — ACO participants typically report APP; non-ACO clinicians cannot.
  14. APM Incentive Payment phase-out confusion — many clinicians don't recognize the transition to Qualifying APM Conversion Factor differential in PY 2024.

Frequently Asked Questions

Q1: What is the Medicare Quality Payment Program (QPP)?

A: QPP is the Medicare Part B physician quality payment framework established by Title I of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA, Public Law 114-10, April 16, 2015). QPP became operational on January 1, 2017. It has two tracks: the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (Advanced APM) track.

Q2: What did MACRA repeal?

A: MACRA permanently repealed the Sustainable Growth Rate (SGR) formula at Section 1848(f) of the Social Security Act. From 1997 through 2015, the SGR threatened annual Medicare Part B payment cuts; Congress passed 17 "doc fix" bills to avert them.

Q3: What is MIPS?

A: MIPS — the Merit-Based Incentive Payment System — is the QPP track that consolidates legacy programs (PQRS, Value-Based Payment Modifier, Meaningful Use) into a single framework with four performance categories: Quality, Cost, Promoting Interoperability, and Improvement Activities. MIPS produces a Final Score 0-100 that determines payment adjustments up to ±9%.

Q4: What are the four MIPS performance categories?

A:

  • Quality (30% PY 2024): clinical quality measures
  • Cost (30% PY 2024): cost measures calculated from claims
  • Promoting Interoperability (25% PY 2024): certified EHR use
  • Improvement Activities (15% PY 2024): clinical practice improvement attestations

Q5: What is the Performance Threshold?

A: The Performance Threshold is the Final Score level above which clinicians receive positive adjustments and below which they receive negative adjustments. For Performance Years 2022, 2023, and 2024, the threshold is 75 points.

Q6: What is the maximum MIPS payment adjustment?

A: Beginning Performance Year 2022 (Payment Year 2024), the maximum MIPS payment adjustment is ±9% of Medicare Part B payment.

Q7: When are payment adjustments applied?

A: Payment Year occurs two years after Performance Year. PY 2022 → PY 2024 adjustments; PY 2023 → PY 2025; PY 2024 → PY 2026.

Q8: What is the Advanced APM track?

A: The Advanced APM track exempts clinicians from MIPS for sufficient participation in qualifying Advanced APMs. To qualify, clinicians must achieve Qualifying APM Participant (QP) status by meeting payment-amount or patient-count thresholds.

Q9: What are Advanced APMs?

A: Advanced APMs are payment models requiring use of certified EHR technology, payment based on quality measures, and financial risk (or Medical Home Model status). Examples include MSSP BASIC Levels C/D/E, MSSP ENHANCED, ACO REACH, Primary Care First, Kidney Care Choices, BPCI Advanced, and others.

Q10: What is the 5% APM Incentive Payment?

A: For Performance Years 2017-2022, QPs received an additional 5% Medicare Part B payment bonus (paid in Payment Years 2019-2024). The Consolidated Appropriations Act of 2023 (Public Law 117-328, December 29, 2022) extended the APM Incentive Payment to Performance Year 2023 at a reduced 3.5% level.

Q11: What replaces the APM Incentive Payment beginning PY 2024?

A: Beginning Payment Year 2026 (Performance Year 2024), QPs receive a Qualifying APM Conversion Factor differential that is higher than the standard Conversion Factor — a structural payment differential built into the Medicare Physician Fee Schedule formula.

Q12: What is the low-volume threshold?

A: Clinicians are exempt from MIPS if they have:

  • $90,000 or less in Medicare Part B charges, OR
  • 200 or fewer Medicare Part B patients, OR
  • 200 or fewer covered Part B services in the determination period

Q13: Who is subject to MIPS?

A: Physicians, PAs, NPs, CNSs, CRNAs, PTs, OTs, SLPs, audiologists, clinical psychologists, RDs/nutrition professionals, clinical social workers, and certified nurse-midwives — unless exempt through low-volume threshold or QP status.

Q14: What is the MIPS Value Pathway (MVP)?

A: MIPS Value Pathways (MVPs) is a specialty-specific reporting framework introduced for Performance Year 2023. Clinicians select an MVP appropriate to their specialty and report a streamlined measure set within that MVP rather than choosing from the full MIPS catalog.

Q15: How is MIPS budget-neutral?

A: MIPS positive payment adjustments are funded by MIPS negative payment adjustments. The system is designed to balance — total positive adjustments cannot exceed total negative adjustments. The Exceptional Performance Bonus (added by MACRA for high performers) was funded through a separate pool through Performance Year 2022, then ended.

Q16: What is the APM Performance Pathway (APP)?

A: APP is the quality reporting pathway for ACO participants. MSSP ACOs report through APP. APP uses a streamlined measure set focused on high-value clinical and patient experience measures.

Q17: Can MSSP BASIC Level A or B qualify as Advanced APM?

A: No. BASIC Levels A and B are upside-only and do not qualify as Advanced APMs. Only two-sided MSSP tracks (BASIC C/D/E and ENHANCED) qualify.

Q18: What is a Partial QP?

A: A Partial Qualifying APM Participant meets lower thresholds than full QPs — exempt from MIPS but does not receive APM Incentive Payment. Partial QPs may elect MIPS reporting.

Q19: How can I find my MIPS performance feedback?

A: Log in to qpp.cms.gov with your CMS Enterprise Identity Management (EIDM) credentials to view MIPS performance feedback, scores, and payment adjustment information.

Q20: Who can I call with QPP questions?

A: The QPP Service Center at 1-866-288-8292 handles technical questions about participation, scoring, and payment adjustments.

Q21: How does QPP affect Medicare beneficiaries directly?

A: Indirectly. QPP determines how Medicare Part B pays clinicians, which affects clinician participation patterns, practice viability, and care delivery investments. Beneficiaries' Medicare benefits are not directly changed by QPP.

Q22: What was the Bipartisan Budget Act of 2018's impact?

A: BBA 2018 (Public Law 115-123, February 9, 2018) modified QPP — allowed gradual Cost category weighting, modified low-volume threshold rules, permitted virtual group reporting, and other technical refinements.

Q23: What was the Consolidated Appropriations Act of 2023's impact?

A: CAA 2023 (Public Law 117-328, December 29, 2022) extended the 5% APM Incentive Payment (at a reduced 3.5% level) through Performance Year 2023, providing one additional year of incentive payments while the Qualifying APM Conversion Factor differential infrastructure rolled out.

Q24: How does QPP relate to MSSP and ACO REACH?

A: Two-sided MSSP tracks (BASIC C/D/E and ENHANCED) and ACO REACH (Professional and Global) qualify as Advanced APMs. Clinicians participating sufficiently in these models may achieve QP status, exempt themselves from MIPS, and receive the APM Incentive Payment (PY 2017-2023) or Qualifying APM Conversion Factor differential (PY 2024+).

Q25: Why does QPP matter for Georgia clinicians?

A: QPP determines Medicare Part B payment for virtually all Georgia clinicians not exempt through the low-volume threshold. MIPS payment adjustments reach ±9%. Major Georgia integrated systems manage QPP performance for thousands of clinicians; independent practices face heavier compliance burdens. Advanced APM participation through MSSP or ACO REACH ACOs provides a path to MIPS exemption and payment incentives.

Call to Action — Contacts and Resources

If you have questions about Quality Payment Program participation, MIPS, Advanced APMs, or how QPP affects your practice or your provider:

  1. QPP Service Center: 1-866-288-8292 — technical questions on participation, scoring, payment adjustments
  2. Medicare: 1-800-MEDICARE — Medicare.gov
  3. GeorgiaCares SHIP: 1-866-552-4464 — free Medicare counseling
  4. Quality Payment Program website — qpp.cms.gov
  5. CMS Medicare Learning Network (MLN) — for educational materials
  6. Palmetto GBA Part A/B MAC: 1-866-238-9650
  7. Medical Association of Georgia (MAG)
  8. Georgia Composite Medical Board — for licensure
  9. Medicare Rights Center: 1-800-333-4114
  10. Acentra Health QIO: 1-844-455-8708
  11. Atlanta Legal Aid: 404-377-0701
  12. Georgia Legal Services: 1-800-498-9469
  13. Eldercare Locator: 1-800-677-1116
  14. 211 Georgia — 211
  15. SSA: 1-800-772-1213
  16. BCRC (Medicare Secondary Payer): 1-855-798-2627
  17. HHS OIG Hotline (for suspected fraud): 1-800-HHS-TIPS

The Medicare Quality Payment Program is the operational reality of Medicare Part B physician payment in the United States. Every Georgia physician, advanced practice provider, therapist, and other Part B clinician is either subject to MIPS, qualifying as a QP under the Advanced APM track, or exempt through the low-volume threshold. Understanding QPP — its statutory roots in MACRA 2015, its operational architecture, its evolution through BBA 2018 and the Consolidated Appropriations Act of 2023, and its connection to MSSP and ACO REACH — is essential for every Georgia clinician and informative for every Georgia beneficiary whose care depends on a Part B clinician.

The repeal of the Sustainable Growth Rate in April 2015 ended nearly two decades of perennial Medicare Part B payment crisis. The Quality Payment Program that replaced it has not been without its own challenges — MIPS scoring complexity, Advanced APM threshold administration, and the transition from incentive payments to conversion factor differentials have all generated controversy. But QPP is the framework Georgia clinicians must navigate, and understanding it well is the difference between maximizing performance-based payments and absorbing avoidable downward adjustments.

BC

Brevy Care Team

Expert eldercare guidance from Brevy's team of healthcare professionals and researchers.