MIPS APM Scoring Standard: Medicare ACO Considerations

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Every MIPS-eligible clinician has several choices for the evaluation of the quality of care they are practicing. Most of the time, we distinguish them as MIPS APMs or Advanced APMs. However, they meet the same fate every time they report their performance data. And, they get specific performance-based outcomes. All MIPS-eligible clinicians necessarily have a particular Tax Identification Number. They customarily bill under this TIN and associate their TIN with others. For instance, they become Medicare ACO for their participation in the Medicare Shared Saving Program (MSSP).

It is the CMS that mainly evaluates the provider’s performance in a variety of ways. It establishes a fine data collection of both MIPS APMs and Advanced APMs. Here, we will see the MIPS APM scoring standard for a Medicare ACO. Just to avoid any ambiguity, let us quote here that we will use the performance year 2017’s data for the payment year 2019’s ACO scoring. Nonetheless, MSSP has modified itself currently and PFS for ACO Medicare entities has brought up new challenges.

Composite Performance Scoring (CPS) for Every Medicare ACO

As we know, Medicare ACO is a single unit but it includes several TINs in it. Every TIN or NPI is assigned to a clinician. Generally, the MIPS CPS is calculated by CMS once at the APM entry level. This CPS scoring applied to MIPS-eligible clinician scores in a group as well.

For Medicare ACO participation in the 2019 payment year, there was no hard and fast clarity about ACO expenditures. CMS has not mentioned whether ACOs will receive any additional bonuses. So, this might be taken as they will be considering MIPS APM Scoring Standard as their spending for establishing benchmarks. Later, the National Assembly of ACOs (NAACOS) strictly opposed it.

MSSP Quality Reporting and Benchmark

The quality category for MIPS APMs makes up 50% of the total in the Scoring Standard for PY 2022. However, CMS has allowed Medicare ACO to report via CMS Web Interface measures. Thus, they got permission to report on behalf of MIPS-eligible clinicians in their organization. Remember here, CMS has closed the CMS Web Interface for Traditional MIPS reporting from 2023 PY.

Anyhow, in previous years, CMS has not even specified the quality performance category requirements and benchmarks. Here, it has favored the utility of MSSP quality benchmarks for every Medicare ACO and all other eligible clinicians (using the Web interface for MIPS).

ACOs have one reporting benefit above all. CMS awards them additional bonus points as per MIPS APM Scoring Standard. The only condition was reporting high-priority measures in the Web Interface measure set at that time. Likewise, MIPS APMs get points ranging from 1 to 10 for reporting 3 eCQM/CQM measures.

Clinical Practice Improvement Activities (CPIA) Reporting

CMS has provided MIPS-eligible clinicians with a new subject of measurement in the form of CPIAs. At that time, reporting CPIAs was a good opportunity for ACOs. Since they were getting a total of 30 or half points automatically for doing so. Thus, being associated with a Medicare ACO was a great leverage for eligible clinicians.

Because this adds to the Medicare ACO reporting requirements, NAACOS has argued about it. It mentioned that they should be given full credit in this area for their participation in the MSSP and/or Next Generation Models. Both these Models include practice improvement as one of their core objectives. Hence, ACOs shouldn’t be subjected to an additional reporting obligation.

For MSSP ACOs, CPIA reporting will be handled by each of the billing TINs connected to the Medicare ACO. Anyhow, as stated, performance will be evaluated as an ACO. One ACO-level score will be generated by summing, weighting, and aggregating each participant’s TIN score from the ACO. For this category, Next Generation ACOs will be required to have their physicians submit individual-level data. The scores of all MIPS-qualified clinicians within the Next Generation ACO will then be combined. Afterward, the score will be averaged to get the ACO score for the Payment year 2019 MIPS APMs.

Report on Meaningful Use Measures as Advancing Care Information (ACI)

The Centres for Medicare and Medicaid Services has included Meaningful Use measures in another performance category. This new arrival category is Advancing Care Information (ACI). However, there were a few ambiguities regarding the effect and implementation of this category. So, NAACOS has addressed the issues at that time and confirmed that there is no further reporting of evaluations for the ACI category except one. This implies that half of the eligible clinicians in a Medicare ACO must take part in Meaningful Use measures. Meanwhile, CMS has announced that it will revise the ACI category in the coming years. This revision may include the finalization of a Base Score or a Performance Score for the ACI category scoring.

ACI Highlights for MSSP ACOs and Next Generation ACOs

  • The APM Entity group’s MIPS-eligible clinicians will all submit data following MIPS’s specifications.
  • Through the billing TINs connected to the ACO for MSSP, performance will be evaluated on a collective basis.
  • One ACO group score will be generated from the weighted average of all of the ACO member group billing TIN scores.
  • A score of 0 is added for each ACO-qualified clinician who does not report this category.


Medicare ACO asks its eligible clinicians to participate in MIPS as MIPS APMs. Here MIPS APMs are the hybrids. They are eligible for reporting in both MIPS and advanced APM pathways. But when a participant becomes eligible for both, they can act as MIPS APMs. In such a case, their reporting rules vary a little bit. Thus, the blog has leveled all the considerations that were made for Medicare ACO in MIPS APM Scoring Board. For more queries, you can either visit the official website of NAACOS or get assistance from our ACO consulting services. ACO reporting in 2023 has however made several modifications to allow more and more clinicians to associate their TINs with Medicare ACOs.

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