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What is the best reporting structure to ensure that targeted services are delivered without causing undue or excessive documentation

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ACOs must submit the quality data via the APM Performance Pathway (APP) established under 414.1367 of this chapter to satisfactorily report on behalf of the eligible clinicians who bill under the TIN of an ACO participant for purposes of the MIPS Quality performance category of the Quality Payment Program

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Under the proposed revisions, if a beneficiary voluntarily aligns to a Shared Savings Program ACO under 425.402(e), we would not assign the beneficiary to that Shared Savings Program ACO when the beneficiary is also eligible for claims-based assignment to an entity participating in a model tested or expanded under section 1115A of the Act under which claims-based assignment is based solely on (1) claims for primary care and/or other services related to treatment of one or more specific diseases or conditions targeted by the model or (2) claims for services other than primary care service, and for which there has been a determination by the Secretary that waiver of the requirement in section 1899(c)(2)(B) of the Act is necessary for purposes of testing the model

However, such risk is not applicable in an FFS payment structure