CMS Releases All-Payer Guidance

The Centers for Medicare and Medicaid Services (CMS) is collecting information and documentation to determine whether payment arrangements qualify as Other Payer Advanced Alternative Payment Models (APMs) under the Quality Payment Program.

Payers with commercial payment arrangements may submit Other Payer Advanced APM determination requests for those payment arrangements. CMS released a document to guide payers through the All Payer submission form. Commercial payment arrangements must be submitted by June 1, 2019 to be eligible for the 2020 Qualifying APM Participant (QP) Performance Period. For the 2020 QP Performance Period, payers may submit requests until June 1, 2019.

Submission through the Other Payer Advanced APM determination process is separate from the process of Medicare Health Plans (including Medicare Advantage plans) payment arrangements. The Medicare Health Plans application is occurring now through the Health Plan Management System bidding process with a due date the first week of June. The Other Payer Advanced APM determinations is occurring now through the Salesforce Portal with a due date of June 1, 2019.


For more information visit the McDermottPlus Payment Innovation Resource Center or contact Mara McDermott at 202-204-1462 or