As we reported last month, CMS’ proposed rule updating MACRA’s Quality Payment Program (“QPP”) for CY 2018 would extend and expand exceptions that would allow many practitioners to avoid participating in its Merit-based Incentive Payment System (“MIPS”) during next year’s performance period. In particular, the proposed rule would increase the low-volume threshold for MIPS-participation from $30,000 to $90,000 and present additional opportunities for advanced alternative payment model participation. In 2017, approximately 800,000 practitioners were exempted from MIPS-participation and CMS estimates that an additional 134,000 would be exempted under the proposed rule, leaving less than 40% of eligible practitioners subject to MIPS participation in 2018.
Continue Reading MACRA Update: How to Prepare for Changes in MIPS

On June 20, 2017, CMS released its proposed rule updating MACRA’s Quality Payment Program (“QPP”) for CY 2018. At over 1,000 pages, the rule might not do much to simplify the already complex requirements of the QPP; however, it would expand and extend the flexibility offered by CMS to practitioners in the 2017 performance period into the 2018 performance period, potentially reducing the program’s immediate burden. Nevertheless, as CMS’ ramp-up to full implementation of the program continues, practitioners should use any flexibility offered in the 2018 performance period as an opportunity to prepare for the imposition of potentially more onerous requirements in the 2019 performance period.
Continue Reading MACRA Quality Payment Program Update

With all the talk of the Affordable Care Act’s uncertain future, it is easy to forget about the Medicare Access and CHIP Reauthorization Act (“MACRA”), a bipartisan law passed by Congress in 2015 to change the way physicians will be reimbursed by Medicare. MACRA is a complex and confusing law. A new study published by Health Affairs in April 2017, which used the RAND Corporation’s Health Care Payment and Delivery Simulation Model (the “Study”), has estimated the potential effects of MACRA payment models on physician and hospital Medicare reimbursement revenue. The results: uncertain.
Continue Reading The Financial Impact of MACRA – Uncertainty Reigns in a Recent RAND Corporation Study

On Friday, October 14, 2016, CMS released the much-anticipated final rule (the “Final Rule”) implementing the Quality Payment Program (QPP), mandated by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).  Pursuant to MACRA and the Final Rule, most clinicians will be required to participate in either a new Merit-based Incentive Payment System (MIPS) or an Advanced Alternative Payment Model (Advanced APM).  The Final Rule’s provisions are set to go into effect on January 1, 2017.  CMS will consider comments on the Final Rule submitted within 60 days of its publication (December 13, 2016).
Continue Reading The MACRA Final Rule: The Art of the Transition

On April 27, 2016, the Centers for Medicare & Medicaid Services (CMS) issued proposed regulations (Proposed Regs.) as a first step in the implementation of the Quality Payment Program (QPP) provisions of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).  In response to public comments regarding the Proposed Regs., CMS announced on September 8, 2016 (QPP Notice) that the final QPP regulations which CMS intends to issue in November, 2016 will allow physicians to “pick their pace” of QPP participation for the first MACRA performance period beginning on January 1, 2017.
Continue Reading CMS says to physicians: Pick your pace for MACRA implementation. Physicians say to CMS: Thank you for hearing us.

The Medicare Board of Trustees is calling for urgent legislative action to address the impending financial insolvency of the Medicare hospital benefit program. The Board’s 2016 report reveals the trust fund that pays for hospital services under Medicare Part A will be depleted by year 2028. At that time, the report indicates Medicare revenue will cover only 87% of payments for anticipated hospital benefits. Although the Trustees have projected inadequate Medicare financing in the past, this year’s insolvency projection comes in two years earlier than last year’s report.
Continue Reading Medicare Board of Trustees Releases 2016 Annual Report: Hospital Trust Fund Insolvency Projected by 2028

The Medicare Access and CHIP Reauthorization Act (MACRA) is expected to drastically change how physicians are paid by the Centers for Medicare and Medicaid Services (CMS). Under the proposed rule, physicians will be given the choice between two payment models: alternative payment models (APMs) and the Merit-Based Incentive Payment System (MIPS).  CMS predicts a majority of physicians will elect to follow MIPS when the new payment models go into effect in January 2019.
Continue Reading CMS Redefines Alternative Payment Models and Offers Option for Merit-Based Incentive Payment System in New Proposed Rule