Updates
July 2017
MACRA: Proposed Changes to Alternative Payment Model Track

The Centers for Medicare & Medicaid Services (CMS) recently published a proposed rule with comment period outlining proposed refinements to the “Quality Payment Program” (QPP) authorized by the bi-partisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) legislation.

CMS outlined proposed changes to the QPP’s Alternative Payment Model (APM) and Merit-Based Incentive System (MIPS) tracks.  The proposed rule describes changes that would be made to the QPP beginning in 2018 that are designed to continue implementation while lessening the program’s complexity and burden.  
Overall, CMS has sought to address numerous APM-track implementation details in the proposed rule, while concurrently seeking to harmonize, to the extent practical, requirements applicable to Medicare and other payer arrangements. Despite the proposed rule’s potential benefits, the QPP, the APM track and its interplay with other payment models will continue to require attention to a complex mix of regulatory, operational and other details to promote success.  Perhaps central to these will be the need for attention to both strategic (i.e., long term) and tactical (i.e., near term) issues in connection with the organization and operation of delivery systems.  

This article focuses on proposed refinements to the APM track, possible implications and changes that might be proposed by health care providers during the regulatory comment period ending Aug. 21.  A forthcoming alert will examine proposed changes to the MIPS track in 2018. 


The full e-alert is available here.  

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