If You Bill Under More Than One TIN, This APM Proposal Is for You

CMS wants to close a loophole in how Advanced APM incentives get paid, and the fix could change your MIPS exemption status

Buried inside the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P) is a change that sounds technical but has real financial teeth: CMS wants to move Qualifying APM Participant (QP) determinations from the NPI level to the TIN/NPI level.

Here's why that matters. Under current policy, if a clinician earns QP status through an Advanced APM, say, through an ACO relationship at one practice, that status, and the MIPS exemption and higher conversion factor that come with it, currently apply to every TIN that clinician bills under, even practices with zero Advanced APM participation. CMS's proposed fix directs the incentive only to the TIN(s) actually doing the work.

If you're a clinician who splits time across a hospital-employed role and a private practice, or across multiple group affiliations, this is not a technicality. It's a redraw of who's exempt from MIPS and who gets the better conversion factor.

The bigger number behind the proposal

CMS frames this alongside a broader reform of the APM Incentive Payment calculation, which the agency estimates would otherwise result in $2.38 billion in windfall payments over the next decade to clinicians who aren't meaningfully participating in an Advanced APM.

Read together, these two proposals are a single message: CMS wants Advanced APM incentives to track actual participation, not administrative artifacts of how a clinician's billing is structured.

The conversion factor backdrop

This runs counter to a two-track conversion factor system that's now in its second year. For CY 2027, CMS proposes:

A qualifying APM conversion factor of $33.17, down $0.40, or 1.19%, from the current $33.57.

A non-qualifying conversion factor of $32.84, down $0.56, or 1.68%, from the current $33.40.

Both are down year-over-year, mostly because the one-time 2.5% payment bump Congress provided for 2026 expires. But the QP track still comes out ahead, and that gap compounds every year.

If TIN/NPI-level determination goes through, staying on the right side of it requires knowing exactly which of your billing relationships actually carries Advanced APM participation.

Updated QP and Partial QP thresholds

The Consolidated Appropriations Act, 2026, also forces a change to the QP/Partial QP threshold schedule. Under the proposal, the thresholds dip back down for the 2026 performance year before returning to the higher 75%/50% (QP) and 50%/35% (Partial QP) levels for 2027 and beyond.

This is worth checking against your own APM Entity's participation data rather than assuming last year's numbers still apply.

A new incentive for ACO and LEAD Model longitudinal care

On the positive side, the rule proposes converting the G2211 E/M complexity add-on from a flat-rate code into a percentage modifier, MOD1, worth +16%, and creating a second, voluntary modifier, MOD2, worth +32%, available only to clinicians in a Shared Savings Program ACO or a LEAD Model ACO.

It's explicit recognition that longitudinal, total-cost-of-care accountability carries real overhead, and it can be billed for any beneficiary the participant serves, not just ACO-assigned ones, though those claims do flow into assignment and benchmark calculations.

What to check before you comment

If your practice has clinicians with multi-TIN billing arrangements, this is the moment to map exactly which TINs carry Advanced APM participation and which don't.

The TIN/NPI proposal could change your MIPS exemption status, your applicable conversion factor, and your reporting obligations starting as early as the CY 2027 performance period.

Comments are due September 14, 2026.

Chirpy Bird, Inc. helps healthcare organizations model the financial impact of APM and MIPS policy changes before they hit your bottom line. Want a second set of eyes on your TIN structure? Reach out.