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