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August 13, 20265 min readSubscribers

Medicare Will Not Call You About the Last APM Bonus

CMS published the 2026 APM incentive advisory Thursday: the final lump sum in the program's history, 1.88 percent of a qualifying clinician's 2025 professional charges, sitting undisbursed because the agency cannot match a tax ID to the clinician who earned it. Nothing gets mailed, nobody gets called, and on October 13 the claim is forfeited. Four other CMS clocks stop the same day, and the one that matters most closes sooner.

MACRA promised a 5 percent lump sum to any clinician clearing the Advanced APM thresholds, and it paid that rate for payment years 2021 through 2024. Then 3.5 percent for 2025, and 1.88 percent for 2026.

Then nothing. CMS says so itself in Thursday's notice: the incentive covers "payment years 2019 through 2026, which respectively correspond to the QP performance periods for 2017 through 2024."

So the check that went out this spring was the last one the program will ever write. And some of it never landed.

The bonus with no follow-up call

The advisory published Thursday at 91 FR 52305 as CMS-5547-N, applicable the day it ran, and its subject is an accounting problem: "When CMS processed the 2026 APM incentive payments, CMS was unable to identify a taxpayer identification number (TIN) or TINs associated with some QPs and was therefore unable to disburse the payment."

For scale, the CY 2026 fee schedule final rule put 528,827 eligible clinicians (TIN-NPIs) at QP status for the 2024 performance period.

CMS has not published how many of those it cannot pay. It has published the consequence.

"All information must be received by October 13, 2026. After that date, any claim to an APM incentive payment for the 2026 payment period based on an eligible clinician's QP status for the 2024 QP performance period will be forfeited."

And the sentence your billing manager should read twice, verbatim: "Please note that CMS will not notify you if there is an issue processing your payment."

The rest of this brief is for subscribers.

The impact tables, the code-level detail, and the rest of the analysis sit past this line.

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