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Reading between the many lines in the 1,920-page 2024 Medicare Physician Fee Schedule (PFS) Proposed Rule, one thing is clear: CMS is still struggling to move providers into Advanced Alternate Payment Models (APMs) and keep existing ACOs moving forward on the path to value-based payments. The APP Reporting tug-of-war between CMS and ACOs results in a slight concession for providers worried about difficulty and cost of all-patient APP Reporting.
We’ve seen this before, of course. Remember the delay in sunsetting the Web Interface for ACOs in the 2022 Rule and the retreat from mandatory transition to risk in the 2023 Rule? This year is no different.
The concession in the 2024 Proposed Rule is a new data submission type for ACOs: Medicare Clinical Quality Measures (Medicare CQMs). These measures will allow ACOs to report via the APP, but in a manner that only includes Medicare patients. While a seeming departure from previous APP guidance, Medicare CQMs are less of an about-face than they initially seem. As we know, the devil is in the details, and Medicare CQMs are just one of the seven key components in this Proposed Rule that walk the line between participation goals and value.