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Non-Attorney Professionals

CMS Issues RFI Seeking Comments Regarding MACRA Payment Reforms
September 28, 2015

The Centers for Medicare and Medicaid Services (CMS) today issued a Request For Information (RFI), seeking input regarding implementation of payment systems under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Enacted in April, 2015, MACRA permanently repeals the Sustainable Growth Rate formula for determining Medicare payments for clinicians’ services, establishes a new framework for rewarding clinicians for value over volume, and is designed to streamline other existing quality reporting programs into one new system. (A comprehensive summary of MACRA, prepared by HLB in partnership with ECG Management Consultants, is available here.

Specifically, CMS issued the RFI to obtain input on policy considerations for Alternative Payment Models (APMs) and for physician-focused payment models (PFPMs). Topics of particular interest to CMS include:

(1)  Planning and Implementation issues related to the Merit-Based Incentive Payment System (MIPS

(2)  Requirements to be considered an eligible alternative payment entity and APM participant (QP);

(3)  The relationship between APMs and the Merit-based Incentive Payment System (MIPS); and

(4)  Criteria for providing comments and recommendations on PFPMs.

The RFI is expected to be published in the Federal Register on or about October 1, 2015. Comments must be received no later than 5 p.m., 30 days after date of publication in the Federal Register.

For additional information or assistance with developing comments addressing issues identified in the RFI, please contact one of the following members of HLB's  Medicare Physician Payment Working Group: Bob Lundy (co-chair), Charles Oppenheim (co-chair),  or Karl Schmitz in Los Angeles at 310.551.8111; Marty Corry or William Eck in Washington, D.C. at 202.580.7700; or Ben Durie in San Francisco at 415.875.8500. 


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For media assistance, please contact Maura Fisher at 202-580-7714.