QP vs Non-QP: Which Medicare Conversion Factor Applies

QP vs non-QP is the choice between Medicare's two Physician Fee Schedule conversion factors, starting in 2026: the higher qualifying APM conversion factor pays clinicians CMS has determined to be Qualifying APM Participants (QPs) through an Advanced Alternative Payment Model, and the nonqualifying (non-QP) conversion factor pays everyone else. The RVUs, GPCIs and payment rules are identical, so a QP's rate for any code is the non-QP rate scaled by the ratio of the two factors. If you haven't been told you're a QP, use non-QP.

What QP and non-QP mean

The Quality Payment Program (QPP) created by MACRA has two tracks. Most clinicians are in the Merit-based Incentive Payment System (MIPS) or exempt from it. A smaller group participates in Advanced APMs: payment models in which the participating entity takes on financial risk for cost and quality, such as some accountable care organization tracks.

A Qualifying APM Participant (QP) is, in the regulation's words, "an eligible clinician determined by CMS to have met or exceeded the relevant QP payment amount or QP patient count threshold" (42 CFR 414.1305). Being in an Advanced APM isn't enough on its own. Enough of the clinician's Medicare business has to run through it.

From 2026 that status changes the conversion factor. CMS's payment file notes: "Beginning January 1, 2026 a differential conversion factor applies when services are furnished by an eligible clinician who is a Qualifying Alternative Payment Model (APM) Participant (QP) for the year." Everyone else, including clinicians in MIPS, MIPS APMs and Partial QPs, is paid with the nonqualifying factor.

Who qualifies: the QP thresholds

CMS measures each clinician's Advanced APM participation during the QP Performance Period, January 1 through August 31, at three snapshots: March 31, June 30 and August 31. A clinician qualifies by meeting either test (42 CFR 414.1425, 414.1430):

• Payment amount: the share of Medicare Part B payments for covered professional services furnished through the Advanced APM entity.
• Patient count: the share of Medicare patients seen through it.

Under the Medicare Option, the thresholds are set by payment year:

The higher thresholds for the 2027 payment year are already written into the regulation (42 CFR 414.1430). The AMA's analysis of the final rule warns of "considerable uncertainty among physicians in advanced APMs about reaching QP thresholds."

Starting with the 2026 QP Performance Period, CMS calculates both an APM Entity-level score and an individual score for each clinician, and a clinician can qualify under either (42 CFR 414.1425(c)(3)(ii); CY 2026 PFS final rule). There's also an All-Payer Combination Option that counts other payers' advanced APMs; it still requires a minimum Medicare share.

The two-year lag

QP status applies to a payment year two years after the performance period it was earned in. The 528,827 clinicians who qualified in 2024 are the ones paid at the 2026 QP conversion factor. The AMA's summary of the CY 2026 final rule puts it this way: they "will receive a higher 3.77 percent update plus a 1.88 percent lump sum bonus payment in 2026."

1. Performance period (year 1, January–August). CMS measures Advanced APM payments and patients at the March, June and August snapshots.
2. Determination. CMS posts QP status by NPI on the QPP Participation Status tool.
3. Payment year (year 3). The clinician's fee schedule services are paid with the QP conversion factor, and they're exempt from MIPS that year.

So QP status for the 2027 payment year depends on 2025 participation measured against the new 75% / 50% thresholds. A clinician who joins an Advanced APM in late 2026 is first measured in the 2027 performance period, which sets the 2029 payment year.

What QP status is worth

Until 2026 the reward for QP status was a lump-sum APM Incentive Payment, a percentage of the prior year's Part B professional payments, paid on top of claims. Starting in 2026 the reward is built into every claim through the conversion factor instead.

Sources: 42 CFR 414.1450(b)(1) for the incentive percentages; CY 2026 PFS final rule for the 2026 factors; CY 2027 PFS proposed rule fact sheet for 2027.

The 2026 gap is small: both factors got the one-time 2.5% increase and the same budget-neutrality adjustment, and differ only by the statutory update (+0.75% vs +0.25%). Because each year's update compounds on the previous year's factor, the gap grows. The 2027 proposed factors are about 1.0% apart. The full build of each factor is in the conversion factor guide.

For a practice that bills mostly office visits, the calculator above turns that percentage into dollars. On a single code it's cents; across a QP's whole Medicare panel it's real money. It's still smaller than the 5% incentive it replaced.

Partial QPs

A clinician who misses the QP threshold but meets the lower Partial QP threshold is a Partial QP. CMS's 2024 results summary is explicit: Partial QPs "can choose whether to participate in MIPS" and "aren't eligible for QP incentives". That means no APM Incentive Payment and no QP conversion factor. For pricing, a Partial QP is non-QP.

Which one to choose in a fee lookup

FeeBase defaults to non-QP. Pick QP only to price services for a clinician who is a QP for the year of the date of service:

1. Most practices: non-QP. Clinicians in MIPS, in MIPS APMs or with Partial QP status are paid at the non-QP rate.
2. ACO and Advanced APM clinicians: check the year. Being in an Advanced APM this year doesn't make you a QP this year. Look up the payment year in the Participation Status tool.
3. Mixed groups: price per clinician. A fee sheet for a group with QPs needs both columns, because the same code pays two amounts depending on who furnished it.

Try the difference on a real code at your ZIP in the Medicare reimbursement rate lookup or the RVU calculator. Both have a QP/non-QP control. The setting matters more than QP status for most codes; see facility vs non-facility.

Where the split shows up in CMS files

• RVU files. From 2026 each quarterly PFS relative value release has two payment files, one for QPs and one for everyone else (PPRRVU…_QPP and PPRRVU…_nonQPP). The RVUs match; the conversion factor differs.
• National payment amount files. "The -QP file contains fees with the differential payment, whereas the -nonQP file contains the standard fees" (CMS PFREV26D).
• MAC fee schedule database. CMS added a pricing indicator to the MPFSDB layout: "1 = QPP indicator applies to qualifying providers", "9 = Concept does not apply" (Pub. 100-04 transmittal 13912, CR 14560, effective November 16, 2026).
• Anesthesia. The anesthesia conversion factor is split the same way: 20.5998 for QPs and 20.4976 for non-QPs nationally in 2026, before locality adjustment.

What CMS proposed for 2027

The CY 2027 PFS proposed rule (July 16, 2026, 91 FR 43842) would "apply QP and Partial QP status to the TIN/NPI under which a clinician achieves QP or Partial QP status," so that "only TINs participating in Advanced APMs receive additional incentive payments, both the APM Incentive Payment and the qualifying APM conversion factor." A QP who also bills under a second, non-APM tax ID would be paid non-QP rates there. CMS also notes that "only legislation enacted by Congress can make changes to either the enhanced QP conversion factor updates or the APM Incentive Payment." These are proposals until CMS finalizes them.

Sources: 42 CFR 414.1305, 414.1425, 414.1430 and 414.1450 (eCFR, current as of October 8, 2026); CY 2026 PFS final rule (CMS-1832-F); AMA, 2026 Medicare Physician Payment Schedule final rule summary; CMS, 2024 QPP Participation and Performance Results At-a-Glance (May 2026); CMS PFREV26D national payment amount file; CMS Pub. 100-04 transmittal 13912 (CR 14560, September 14, 2026); CY 2027 PFS proposed rule, 91 FR 43842. Verified October 8, 2026.