Topic Thread

1.  Question about ACO Track 1 participation

Posted 12 days ago

 We have a couple of different scenarios of ACO Track 1 participation;

  1.  We participate in one ACO Track 1 where our TIN is broken up; all our PCP participates in the ACO and all our Specialists are full MIPS participates. Note all these providers practices under the same TIN. The ACO will submit for Quality data and the IA is included, and we will be submitting the ACI for PCPs. Since our specialists does not participate in the ACO and are required to submit full MIPS, are we allowed to do individual submission for this, which would mean that the PCPs will also submit individual ACI data? The reasoning behind this is that the majority of our specialist are excluded from MIPS if submitted as an individual, but I'm trying to understand if you can participate in ACO Track 1 (considered as a group) and do individual MIPS submission for ACI?
  2. We have another ACO Track 1 scenario where all our providers in the TIN is included. Same scenario here, ACO will handle submission for Quality data and the IA is included and we are submitting ACI. The majority of the providers in this group are excluded from MIPS participation due to low volume, but since they participate in an ACO and will submit data through them would we need to submit ACI data even if they are excluded from MIPS?

Maria Boyd
Director of Credentialing Independence Physicians Management LLC


2.  RE: Question about ACO Track 1 participation

Posted 12 days ago

Hi Maria,

Thanks for these questions. Group-level reporting decisions must be made for each TIN, and how one TIN reports would not impact another TIN. TINs participating in an MSSP ACO are required to report ACI data at the TIN-level, and that data would be evaluated at the ACO-level. If a group reports at the TIN-level, the low-volume threshold would be assessed at the TIN-level, which means all clinicians billing under that TIN would either all be excluded or none would be excluded. You can look up MIPS participation information evaluated at the NPI and TIN levels at the CMS website.

I hope this information is helpful! If you have more questions about your scenario, please feel free to reach out to


Suzanne Falk
Associate Director, MGMA Government Affairs