CMS can't find billing details for some 2026 APM bonus recipients: update by October 13 or forfeit the 1.88% payment

“Please note that CMS will not notify you if there is an issue processing your payment.” That line closes the instructions in a Medicare payment advisory CMS published August 13, and it sets the terms for clinicians who earned a 2026 Advanced APM bonus but have not received it [1].

What changed

CMS says it could not match some qualifying APM participants (QPs) to a taxpayer identification number (TIN), so it could not pay their 2026 APM incentive payment [1]. The advisory, file code CMS-5547-N, asks those clinicians, and anyone else who expected the payment and did not get it, to send current Medicare billing information by October 13, 2026 [1]. After that date the claim is forfeited, and CMS “will not accept requests for additional payment review or reprocessing” [1].

The payment is 1.88% of the clinician’s estimated aggregate paid amounts for Part B covered professional services furnished in calendar year 2025 [1].

Who it affects

The advisory covers clinicians who reached QP status in the 2024 performance period [1]. A QP is an eligible clinician in an Advanced Alternative Payment Model (APM) who met the payment amount or patient count thresholds for the year [1]. Advanced APMs are payment models with, in CMS’s words, “features to ensure accountability for quality and cost of care” [4]. The incentive goes only to full QPs; Partial QPs do not get it [2].

CMS pays the lump sum to a TIN, not to the individual. Its rules send the payment first to the TIN tied to the clinician’s Advanced APM entity, then down a hierarchy to other TINs where it can find the clinician billing [2]. CMS added that hierarchy because, as it explains in this summer’s fee schedule proposal, “clinician movement, changes to a practice’s TINs” meant it could not always pay the APM-linked TIN [2]. The clinicians on the new list are the ones for whom CMS found no TIN at all [1].

That points to a predictable group: physicians and other clinicians who left an ACO or other Advanced APM practice after 2024, retired, moved to a new group or a new TIN, or whose group reorganized. The practice that employed the clinician in 2024 may not be the one that receives the money.

CMS has not published how many clinicians are on the list or the total amount owed. For scale, it projects between 517,800 and 530,900 clinicians will become QPs for the 2026 performance period [2].

Is there an APM incentive payment in 2027?

No. The lump sum has been cut and extended several times, and the schedule now has a gap. The payment was 5% for payment years 2019 through 2024, 3.5% for 2025 and 1.88% for 2026 [2]. The Consolidated Appropriations Act, 2026, signed February 3, added a payment “with respect to 2028, 3.1 percent” in section 6204 [3]. Nothing covers payment year 2027, which corresponds to the 2025 performance period. CMS’s proposed regulatory text lists the years as “2019 through 2024: 5 percent,” “2025: 3.5 percent,” “2026: 1.88 percent” and “2028: 3.1 percent” [2].

The same law set the QP thresholds for the 2026 performance period at the lower levels used in earlier years: 50% of Part B payments or 35% of Medicare patients through Advanced APMs, with Partial QP thresholds of 40% and 25% [2, 3]. For the 2025 performance period the bar was 75% and 50%, and it returns to those levels in the 2027 performance period [2].

A separate reward also started in 2026. QPs are paid under their own fee schedule conversion factor, which rises 0.75% a year, against 0.25% for everyone else [2]. For 2027, CMS proposes a qualifying APM conversion factor of $33.17 and a non-qualifying one of $32.84 [4]. We covered that proposal in our report on the 2027 fee schedule.

What it means for your practice

Money is sitting unclaimed. At 1.88%, a clinician with $300,000 in 2025 Part B paid amounts for covered professional services would be owed about $5,640, by our arithmetic.

Silence is not confirmation. CMS will hold everything received by October 13 and process it after the window closes, and it will not tell submitters about problems [1]. Last year’s advisory, published July 30, 2025, set a September 1, 2025 deadline and warned that validation could take up to three months before payments went out [5]. A practice that submits and hears nothing should not assume the payment went through.

Banking changes are a common snag. If your banking information changed in the past year, CMS “strongly” recommends sending a voided check along with Form CMS-588 to help avoid payment delays [1].

QP status carries more than the bonus. Clinicians who become QPs for a performance period are excluded from MIPS reporting requirements and payment adjustments for the matching MIPS year [2]. A clinician who misses the QP thresholds but reaches Partial QP status can choose whether to report to MIPS; one who reaches neither is subject to MIPS unless another exclusion applies [2].

Former clinicians are part of the picture. If a QP left your group, the payment could depend on whether they update their own information. If a QP joined your group, your TIN could be where CMS sends it.

The 2028 payment is being earned now. QP determinations use claims at three snapshots, March 31, June 30 and August 31, in a performance period that runs January 1 through August 31 [2]. The final 2026 snapshot falls on August 31, and QP status from 2026 is what drives the 3.1% payment in 2028 [2, 3].

What to do now

1. Check the list. The advisory links to a CMS file, the “2026 QP Notice for APM Incentive Payment,” naming QPs CMS could not pay, along with submission instructions [1]. Look for every clinician who billed under your TIN in 2024 or 2025.
2. Submit before October 13. Follow the QPP instructions and include all required documents [1]. Questions go to the QPP Help Desk at 1-866-288-8292 [1].
3. Send banking proof if anything changed. Attach a voided check and Form CMS-588 [1].
4. Reach out to departed clinicians. Give them the deadline; a claim after October 13 is forfeited [1].
5. Watch the 2026 participation lists. A clinician must appear on an APM entity’s participation list on a snapshot date to be assessed for QP status [2].

The policy fight

The bigger argument is over where QP rewards should land. In the CY 2027 fee schedule proposal, CMS proposes that starting with the 2027 performance period, QP and Partial QP status would apply only at the TIN where the clinician participates in the Advanced APM, not to every TIN the clinician bills under [2]. CMS says the current approach risks paying “a significant proportion of incentives” to TINs that are not part of an Advanced APM, “creating a disincentive for these TINs to join” [2]. The agency acknowledges the change could be “perceived as introducing complexity,” since some clinicians would be a QP at one TIN and in MIPS at another [2].

AMGA urged CMS in July “to preserve entity-level Qualifying Participant determinations” [6]. Jerry Penso, MD, AMGA’s president and CEO, also criticized the proposed 2027 updates as “a return to the bare statutory updates required under MACRA” and called for an update tied to the Medicare Economic Index [6].

CMS says the size of the incentive is not its call: “Only legislation enacted by Congress can make changes to either the enhanced QP conversion factor updates or the APM Incentive Payment” [2]. Congress has so far acted one year at a time, most recently skipping 2027 and funding 2028 at 3.1% [3]. Comments on the TIN-level proposal are due September 14, 2026, under file code CMS-1848-P [2].