Impact Insights

2022 PFS Proposed Rule Part 3: APP, Advanced APM and MSSP Proposals

APM Performance Pathway (APP) Proposals

The proposed rule contains a small number of (yet important) changes to APP and Advanced APM regulations:


Currently, MIPS APM participants can report the APP as an individual, a group, or APM Entity.

Additionally with this rule, subgroups are proposed to be available to APPs (as well as MVPs) beginning in PY 2023 (note that subgroups would not be required to register for reporting the APP).

The definition for a subgroup and eligibility to participate as a subgroup are the same for MVP and APP reporting:

A subgroup is defined as “a subset of a group which contains at least one MIPS eligible clinician and is identified by a combination of the group TIN, the subgroup identifier, and each eligible clinician’s NPI.”

Subgroups would inherit the eligibility and special status determinations of the affiliated group (identified by TIN).
▪ To participate as a subgroup, the TIN would have to exceed the low-volume threshold at the group level.
The subgroup would inherit any special statuses held by the group, even if the subgroup composition would not meet the criteria.

Advanced APM Proposals

Hierarchy Changes

▪ Propose adding a hierarchy to identify potential payee Taxpayer Identification Numbers (TINs) in the event that the Qualifying APM Participant’s (QP) original TIN is no longer active to the current regulatory hierarchy for processing the QP Incentive Payment.
– This will make it easier for CMS to complete successful payments to QPs in the event of any QP TIN changes.

Medicare Shared Savings Program (MSSP) Proposals

Web Interface (WI) Extension

▪ CMS is proposing a longer transition to ACO eCQM/MIPS CQM quality measure reporting, and consequently will be extending the CMS Web Interface as an option for two years for ACOs (for performance years 2022 and 2023).
▪ Additionally, CMS is proposing an additional one-year freeze before the phase-in of the increase in the quality performance standard ACOs must meet to share in savings.

MSSP Specifics

Helpful Links

CMS PFS Homepage:

CMS Proposed Rule Page:

PDF of Proposed Rule (1,747 pages):

Federal Register Proposed Rule Page:

CMS Fact Sheet: