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

CMS proposes moving Qualifying APM Participant (QP) determinations from the NPI to the TIN/NPI level—closing a loophole that currently extends MIPS exemptions and higher conversion factors to TINs with zero APM participation. For clinicians billing under multiple TINs, this redraws exemption status and reporting obligations. Paired with a $2.38 billion windfall correction, the message is clear: incentives must track actual participation. The CY 2027 Physician Fee Schedule also adjusts conversion factors ($33.17 QP vs. $32.84 non-QP) and thresholds. Comments are due September 14, 2026.