As Accountable Care Organizations (ACOs) prepare for 2025 performance and payment years, one of the most critical updates relates to Qualifying Participant (QP) determinations under the Quality Payment Program (QPP). These determinations decide whether clinicians participating in Advanced Alternative Payment Models (APMs), including those in the Medicare Shared Savings Program (MSSP), qualify for Advanced APM bonuses and exemption from MIPS reporting.

What Is a QP Determination? A Qualifying Participant (QP) is a clinician or group of clinicians who meet certain thresholds for participation in Advanced APMs, such as the Shared Savings Program’s Track 2, Track 3, BASIC Levels E, and ENHANCED tracks.

In short, QP status reflects whether your organization is generating enough Medicare payments or patient volume through Advanced APM entities to qualify for special payment incentives.

Clinicians can be classified as:

• QP – meeting both thresholds for Advanced APM participation (eligible for APM bonus and MIPS exemption)
• Partial QP (PQP) – meeting some, but not all, thresholds (eligible to opt out of MIPS but no bonus)
• Non-QP – below the minimum thresholds (required to report under MIPS)

How CMS Makes QP Determinations Under 2025 guidance, CMS uses three snapshot periods each performance year to calculate QP status based on Medicare Part B claims and APM Entity submissions. For ACOs, this process is handled through the RFI (Request for Information) Phase 2 submission, where ACOs confirm participating TINs, clinicians (NPIs), and agreements.

Here’s how it works: -Data Collection and Attribution: CMS attributes beneficiaries to APM Entities based on billing and participation lists submitted through RFI Phase 2.

-Threshold Assessment: CMS compares the proportion of:

• Medicare payments received through the APM Entity, and/or
• Beneficiaries attributed through the APM Entity, against QP performance thresholds (updated annually).

-QP Status Calculations: CMS evaluates these ratios at the entity level and then assigns QP or PQP status to each clinician affiliated with that APM Entity.

-Final QP Determination Lists: CMS releases final determinations on the QPP Participation Status Lookup Tool, typically within the third quarter of the performance year.

Where to Check Your QP Status or Eligibility Clinicians and ACO administrators can verify QP status using CMS’s QPP Participation Status Lookup Tool here.

You can search by:

• Individual NPI – to view personal QP, PQP, or MIPS eligibility
• TIN or APM Entity ID – to confirm ACO or group-level participation status

CMS updates this tool throughout the year to reflect snapshot results and final determinations after the RFI Phase 2 submission window.

Why This Matters for ACOs in 2025 For ACOs participating in Advanced APM tracks, maintaining QP thresholds is about both compliance and maximizing rewards.

• QP clinicians earn a lump-sum APM incentive payment two years after the performance year (e.g., a PY2025 payment in 2027).
• Partial QPs can opt out of MIPS, simplifying reporting requirements.
• Non-QPs remain under the MIPS program and must meet all reporting requirements to avoid penalties.

As CMS continues to refine the QP methodology, including potential multi-payer determinations and new APM Performance Pathways (APPs), ACOs must stay ahead by ensuring accurate data submission and clinician alignment through RFI Phase 2.

At Quantician, we help ACOs simplify complex reporting requirements and maintain compliance through seamless data submission, proactive tracking, and transparent performance insight, so organizations can focus on care, not compliance.