Blog: CMS Issues Final MACRA Physician Payment Rule

by Cooley LLP
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On Friday, October 14th, the Center for Medicare & Medicaid Services (CMS) released the long-anticipated final rule with 60-day comment period (Rule) for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Quality Payment Program (QPP). The QPP provides incentive payments for participation in Advanced Alternative Payment Models (Advanced APM).  The provisions of the 2,400 page Rule take effect January 1, 2017.  When fully implemented, the Rule will generally transition providers from the current fee-for-service payment system into new value-based payment models. The Rule eliminates the sustainable growth formula and replaces it with a .5% annual rate increase through 2019, after which physicians are encouraged to shift to one of two new QPPs: (1) Merit-Based Incentive Payment System (MIPS); or (2) Alternative Payment Model (APM).   MIPS eliminates and combines Meaningful Use, the Physician Quality Reporting System and the Value-Based Payment Modifier.

Some of the other significant provisions in the Rule include:

  • To ease reporting requirements for the new payment systems and avoid physician payment cuts, doctors will be given a “pick your pace” approach for the first performance period commencing January 1, 2017. This approach allows providers to report MIPS, based on their ability to collect quality measure data, or the providers can participate in an APM.
  • Smaller providers are afforded relief under MIPS as the low volume threshold is raised. More providers should qualify for exclusion from MIPS. CMS estimates that 380,000 could be exempt. The final threshold allows small practices to be exempt if they have less than, or equal to, $30,000 in Medicare Part B charges or 100 Medicare patients. This amount is an increase from $10,000 in Medicare Part B charges and 100 Medicare patients that was included in the Proposed Rule.
  • To strengthen the movement toward Advanced APMs, the Rule offers potential new opportunities such as the Medicare ACO Track 1.

Industry reaction to the Rule generally was favorable. Congressional reaction was cautious and limited given the size and complexity of the Rule. The House Ways and Means and Energy and Commerce Committees issued a joint release expressing pleasure that CMS “responded to many of our concerns and followed our recommendation to provide clinicians and practitioners more flexibility in the issuance of the final rule for MACRA.”

Key additional guidance and information provided by CMS can be found at the following:

Executive Summary: https://qpp.cms.gov/docs/QPP_Executive_Summary_of_Final_Rule.pdf

QPP Fact Sheet: https://qpp.cms.gov/docs/Quality_Payment_Program_Overview_Fact_Sheet.pdf

List of APMs: https://qpp.cms.gov/docs/QPP_Advanced_APMs_in_2017.pdf

“Where to find help:”: https://qpp.cms.gov/docs/QPP_Where_to_Go_for_Help.pdf

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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