April 29, 2016
On April 27, 2016, the Centers for Medicare & Medicaid Services (CMS) posted a pre-publication version of a proposed rule implementing changes to Medicare payment for physician services authorized under the bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The 962-page, pre-publication version of the proposed rule is available here. CMS is soliciting comments on the rule by a deadline of June 27, 2016.  

The proposed rule outlines CMS’ proposed approach to implementation of the Merit-Based Incentive System (MIPS) and the Alternative Payment Models (APM) required by the MACRA legislation. 

Under MACRA, the MIPS program would subject physicians and certain other professionals to positive, neutral, or negative adjustments to their Medicare fee-for-service reimbursement beginning in 2019, using 2017 data. Providers participating in an Advanced APM would not be subject to the MIPS payment adjustments, but they would instead have the opportunity to receive additional bonus payments and Medicare fee schedule updates in future years. The proposed rule outlines CMS’ views regarding entities that can qualify as Advanced APMs, focusing on Medical Homes and including the requirement that such entities must bear financial risk.   

To view the full alert, click here.