CMS’s proposed CY 2027 Physician Fee Schedule rule could change how Qualifying APM Participant (QP) status is evaluated — shifting from the individual clinician level to the TIN/NPI combination level. For radiology, anesthesia, emergency medicine, and hospital medicine groups that bill under multiple TINs, this shift could mean losing the QP conversion factor and incentive bonus on claims tied to non-APM-participating TINs, even when the clinician’s QP status hasn’t changed.
This white paper breaks down what’s changing, who’s most exposed, and includes an illustrative case study showing the potential financial impact on a multi-TIN group. We also cover the MIPS reversion risk for clinicians who lose QP-rate treatment, and what to do before the September 14, 2026 comment deadline.
Download the white paper to learn:
- Recommended next steps — including how Ventra Health can help assess your group’s specific impact
- How the proposed TIN/NPI-level test works and why it targets multi-TIN groups
- Which specialties face the greatest exposure
- A dollar-figure example of what’s at stake
- The MIPS penalty risk tied to losing QP status
