Share this e-Alert:

Polsinelli - Health Care Polsinelli - Health Care


September 2015


Payment Innovation: 30 Day Window to Provide CMS Comments on Physician Payment Changes Under MACRA Begins






Best Lawyers - Law Firm of the Year - U.S. News and World Report - Health Care Law - 2015


Modern Healthcare - by the numbers 2015 - No. 1 Polsinelli - Largest healthcare law firms


For more information about this e-Alert, please contact:



Bruce A. Johnson



Email | Bio


To learn more about our Health Care practice, to contact one of our Health Care attorneys, or for more Health Care Intelligence, click here.


View Polsinelli documents on JD Supra  


LinkedIn Twitter Facebook Polsinelli Podcast Connect with us on LinkedIn. Connection with us on Twitter. Connect with us on Facebook.

On September 28, 2015, the Centers for Medicare & Medicaid Services (CMS) published a Request for Information (RFI) seeking stakeholder comments related to innovative physician payment models required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The RFI is scheduled to be published in the October 1, 2015 Federal Register with comments due 30 days after publication. The RFI requests comments regarding the Merit-based Incentive Payment System (MIPS) and a number of other programs authorized by MACRA. Under MACRA, the existing CMS Physician Quality Reporting System (PQRS), Value-Based Payment Modifier (VPM) and Electronic Health Records incentive (EHR) programs are sunset. CMS anticipates incorporating aspects of these programs into the new MIPS.

MACRA also requires the following:

  • the development of Alternative Payment Models (APMs);
  • provision for incentive payments to certain eligible professionals participating in APMs; and
  • exemptions of eligible professionals from the MIPS if they participate in APMs.

Under MACRA, incentive payments linked to APM participation will begin for calendar year 2019 in an amount equal to five percent of the estimated aggregate Part B Medicare payment for covered professional services for the preceding year.

The RFI requests input related to Physician-Focused Payment Models and other programs mandated by MACRA, including programs to provide technical assistance to small practices and practices in Health Professional Shortage Areas.

In Conclusion:

Health care organizations that employ or contract with physicians including physician groups, hospitals, clinically integrated networks, accountable care organizations and others may wish to respond to the RFI. The new programs will be developed by CMS, in part, based on the agencies' past experience with similar initiatives. Stakeholders will be well-served to ensure CMS has a full understanding of the experiences, opportunities, and challenges with existing programs and future needs. Polsinelli anticipates assisting health care organizations in responding to the RFI.

To review the Request for Information, click here.

For More Information

For questions regarding this e-blast, please contact one of the authors, a member of Polsinelli's Health Care practice, or your Polsinelli attorney.














Atlanta  Chattanooga  Chicago  Dallas  Denver  Kansas City  Los Angeles  Nashville  New York
Overland Park  Phoenix  Raleigh  St. Joseph  St. Louis  San Francisco  Springfield  Washington, D.C.  Wilmington








real challenges. real answers.SM  
Polsinelli is an Am Law 100 firm with more than 750 attorneys in 18 offices, serving corporations, institutions, entrepreneurs and individuals nationally. Ranked in the top five percent of law firms for client service and top five percent of firms for innovating new and valuable services*, the firm has risen more than 100 spots in Am Law's annual firm ranking over the past six years. Polsinelli attorneys provide practical legal counsel infused with business insight, and focus on health care, financial services, real estate, life sciences and technology, and business litigation. Polsinelli attorneys have depth of experience in 100 service areas and 70 industries. The firm can be found online at Polsinelli PC. In California, Polsinelli LLP.

* BTI Client Service A-Team 2015 and BTI Brand Elite 2015







Polsinelli provides this material for informational purposes only. The material provided herein is general and is not intended to be legal advice. Polsinelli is very proud of the results we obtain for our clients, but you should know that past results do not guarantee future results; that every case is different and must be judged on its own merits; and that the choice of a lawyer is an important decision and should not be based solely upon advertisements.

Copyright © 2015 Polsinelli PC.

Connect with us on LinkedIn. Connection with us on Twitter. Connect with us on Facebook. Polsinelli Health Care Health Care