QPP

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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

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