CMS Advisory Overview

The Centers for Medicare & Medicaid Services (CMS) has released an important advisory notifying certain clinicians who qualified as Alternative Payment Model (APM) participants that they must take immediate action to receive their 2025 incentive payments.

Affected APM Participants

CMS has identified a group of qualifying APM participants (QPs) from the 2023 performance year whose taxpayer identification numbers (TINs) are either missing or unidentifiable. As a result, CMS is currently unable to disburse the 3.5% APM incentive payments owed for the 2025 payment year.

Action Required by September 1, 2025

To avoid forfeiting their incentive payments, affected QPs must:

• Submit their current Medicare billing information, including TINs, using the instructions provided in a separate notification from CMS.
• Ensure all relevant Quality Payment Program (QPP) data from the 2023 clinical performance period is submitted by September 1, 2025.

Failure to provide the required information by the deadline will result in forfeiture of the APM incentive payment for the 2023 performance year.

CMS has made a list of impacted QPs available and is urging all clinicians who expected to receive an APM incentive payment but have not yet received it to verify their status and submit the necessary documentation. 

Processing Timeline

CMS will begin processing all timely submissions after the September 1 deadline. The validation and verification process may take up to three months before payments are issued.

HIM leaders should take note because missed incentive payments can result in a significant loss of expected revenue, potentially up to 3.5% per qualifying clinician . Ensuring timely submission of TINs and quality data helps protect the organization’s reimbursement and supports compliance with value-based care initiatives. Proactively coordinating with clinicians and billing teams now can prevent revenue disruptions and strengthen your organization's performance under future APM reporting cycles.

For questions, providers can contact the QPP Help Desk at 1-866-288-8292.

The complete notice is available here at the Federal Register: https://www.federalregister.gov/documents/2025/07/30/2025-14434/medicare-program-alternative-payment-model-apm-incentive-payment-advisory-for-clinicians-request-for