November 8, 2016
The Centers for Medicare & Medicaid Services (CMS) recently released its final rule with comment period implementing the bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Among its numerous changes, MACRA replaced the Medicare sustainable growth rate (SGR) formula with a new system that links Medicare fee for service (FFS) payments for physician and other clinicians’ services to care delivery, quality and value-based variables.   

This article is part of a three-part series that examines various legal, operational and strategic details and considerations related to MACRA based on the unpublished version of the final rule submitted to the Office of Management and Budget on Oct. 14, 2016. The final rule was is expected to be published in the Federal Register on Nov. 4, 2016.

Specifically, this article examines the Merit Based Payment Incentive System (MIPS) under MACRA and the overall Quality Payment Program (QPP) being implemented by CMS via the final rule.  
Separate articles in this series examine:
  • Essential elements of the QPP, including its policy objectives, alternative participation vehicles, and key operational choices (MACRA Essential Elements), and
  • MACRA’s Alternative Payment Model (APM) participation vehicle.
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