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Implementing the APM Performance Pathway

A decision guide for MSSP ACOs and MIPS APMs


Starting in 2021, CMS launched the APM Performance Pathway (APP) reporting framework to evaluate quality performance in two important Medicare programs:

  • Medicare Shared Savings Program (MSSP): As part of MSSP Accountable Care Organizations (ACOs) participation, the APP is required for clinicians across all tracks of the program.
  • Merit-Based Incentive Payment System (MIPS): In the Quality Payment Program, the APP is optional for eligible clinicians in the MIPS payment track who are participating in a payment model that is considered a MIPS APM.

This APP framework features a single, predetermined measure set that aligns quality reporting requirements between MIPS and MSSP. But there’s more to each program than quality reporting, and that means the considerations clinicians face when implementing the APP depend on whether clinicians participate in MSSP, MIPS, or both.


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