New CMS Proposed Rule Would Refine MACRA

Jun 25, 2017 at 05:33 pm by Staff


From Polsinelli Firm

On June 20, the Centers for Medicare & Medicaid Services (CMS) posted a prepublication version of a proposed rule implementing changes to payment for Medicare Part B professional services authorized under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The proposal would modify provisions of the November 4, 2016 final rule implementing MACRA.

The proposed rule outlines CMS's proposed approach to continued implementation of the two tracks of the Quality Payment Program (QPP), the Merit-Based Incentive System (MIPS) and the Alternative Payment Models (APM), as required by the bipartisan MACRA legislation. The proposal sets forth refinements to MACRA's implementation for 2018 and future years in areas that are generally designed to further minimize the MACRA program's burden and continue a "go slow" approach to implementation.

The proposed rule would further refine how MACRA's MIPS participation alternative would subject certain Medicare Part B providers to positive or negative adjustments to their Medicare fee for service reimbursement in 2020.

Key topics and proposals related to MIPS include:


The proposed rule also outlines CMS' proposed refinements regarding entities that can qualify as Advanced APMs that bear financial risk, with attention to the consideration of commercial and other Medicare program risk-bearing arrangements in connection with such determinations. Under MACRA, providers participating in an Advanced APM will not be subject to MIPS payment adjustments, but they will instead have the opportunity to receive additional bonus payments and Medicare fee schedule updates in future years. Key APM participation track themes in the proposed rule include:


The 1,058 page pre-publication version of the proposed rule is available here. The proposed rule is scheduled to be published in the Federal Register on June 30. Polsinelli will publish a more detailed analysis of the proposed rule, including analysis of potential implications and issues that may be of interest to physicians and other clinicians, health systems, clinically integrated networks and other organizations in early July. We will also be conducting a live webinar on the proposal this summer. Comments on the rule may be provided up to August 21, 2017.

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