Do you belong to a Physician Hospital Organization (PHO) or Accountable Care Organization (ACO)? If so, that could impact your reporting for MIPS. Follow our decision tree to find out what you need to do.

Find out whether your PHO or ACO is part of an eligible Advanced Alternative Payment Model (APM).


YES, my PHO or ACO is part of an eligible Advanced APM
Are you a qualified participant? (You are a qualified participant if you receive 25% of your Medicare Part B payments through an Advanced APM OR you see 20% of your Medicare patients through an Advanced APM.)
If yes, you do not need to participate in MIPS. But you’ll need to send in the quality data required by your Advanced APM; check the requirements on your model’s website.If no, are you a partial qualified participant? (You are a partial qualified participant if you have at least 20% of Medicare Part B payments OR 10% of your Medicare patients flowing through an Advanced APM.)
  If yes, you can choose to participate in or opt out of MIPS.If no, you must participate in MIPS – but you will automatically receive full credit in the Improvement Activities category of MIPS. Depending on your APM, you may report quality measures and be evaluated on ACI performance through the APM as well.


NO, my PHO or ACO is not part of an eligible Advanced APM
Is your PHO or ACO a MIPS APM?

If yes, you need to participate in MIPS – but you will be scored differently in an effort to reduce your reporting burden:

  • The MIPS score will be assessed at the ACO level, NOT the TIN level.
  • The performance categories will be weighted differently:
    • Quality = 50%
    • ACI = 30%
    • Improvement Activities = 20%
  • You will automatically receive full credit for the IA category.
  • Quality data is submitted by the ACO, but ACI data is submitted by each TIN.
If no, you will be a regular participant in MIPS and will receive no special adjustments. Review requirements in the MIPS toolkit.
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