CMS proposes to scale back scope of bundled payment model for joint replacement, cancel other mandatory bundled payment models

The Centers for Medicare and Medicaid Services (CMS) on Thursday, August 17, 2017, published a proposed rule that would reduce the number of geographic areas where hospitals and clinicians would be required to participate in the Comprehensive Care for Joint Replacement (CJR) bundled payment model focused on knee and hip replacements, and cancel cardiac and other orthopedic bundled payment models that are scheduled to begin on January 1, 2018.

As a member of Congress and in his confirmation hearings as Secretary of the Department of Health and Human Services (HHS), Secretary Tom Price raised concerns about regulations issued by the Obama Administration to test the orthopedic and cardiac bundles payment models in so many geographic areas on a mandatory basis.

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CMS proposes changes to MACRA Quality Payment Program for 2018

The Center for Medicare and Medicaid Services (CMS) on June 30, 2017, published a proposed rule outlining changes for the 2018 performance year of the Quality Payment Program (QPP) under the Medicare Access and CHIP Reauthorization Act (MACRA). MACRA’s QPP includes the incentive payments for advanced alternative payment models (A-APMs) and the Merit-based Incentive Payment System (MIPS). Performance in 2018 will determine payment adjustments to clinicians that will be applied to their Medicare Part B payments in 2020.

The first performance year began January 1, 2017, for Part B payment adjustments in 2019.

MACRA repealed the sustainable growth rate (SGR) formula for updates to the Medicare Part B Physician Fee Schedule and sets payment updates for all years in the future. Through the QPP, the law is intended to link Medicare payment updates to quality and performance and drive the health care payment system across all payers away from fee-for-service reimbursement models.

Select key provisions of the proposed rule are highlighted below.

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CMS provides updates on Quality Payment Program and new episode payment models as MACRA pushes forward

In late December 2016, the Centers for Medicare and Medicaid Services (CMS) released additional guidance for implementing the significant law the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) as a follow-up to the Final Rule released in October 2016.

While the fate of other legislation such as the Affordable Care Act is in question, the implementation of MACRA continues to move forward as planned with bipartisan support.  The released guidance includes a number of updates to support providers transitioning to the Quality Payment Program (QPP) established by MACRA, including the 2017 quality measure performance benchmarks to be used in the Merit-based Incentive Payment System (MIPS) and the patient relationship categories and codes used to measure cost under MIPS.

Additionally, CMS finalized three new episode payment models with tracks which may be considered advanced Alternative Payment Models (APMs) for purposes of the QPP, as well as released additional information on the ACO Track 1+ model, which will qualify as an advanced APM in 2018.

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CMS continues push to offer additional Advanced APM options under MACRA

The Centers for Medicare and Medicaid Services (CMS) on Tuesday, October 25, 2016, announced additional options for physicians and other clinicians paid under the Medicare Part B Physician Fee Schedule (PFS) to participate in Advanced Alternative Payment Models (Advanced APMs) in 2017, the first performance year under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). CMS also announced additional options for clinicians to participate in Advanced APMs in 2018.

Under MACRA, Advanced APMs are risk-bearing, coordinated care models that link reimbursement to certain quality and outcomes measures and require the use of certified electronic health record technology (CEHRT).

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CMS locks in January 1, 2017 start date in final rule on new Medicare payment tracks under MACRA

The Centers for Medicare and Medicaid Services (CMS), on Friday, October 14, 2016, issued the heavily anticipated final rule on the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Together, CMS is referring to the new payment tracks through MIPS and Advanced APMs as the Quality Payment Program (QPP).

MACRA repealed the sustainable growth rate (SGR) formula for updates to the Medicare Physician Fee Schedule and sets payment updates for all years in the future. Through the QPP, the law is intended to link Medicare payment updates to quality and performance and drive the health care payment system across all payers away from fee-for-service reimbursement models.

The first performance period under MACRA will begin on January 1, 2017, and the first payment adjustments under the law will take effect for 2019.

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Major health care regulatory activity still to come under the Obama Administration

As many in the US prepare to shift their attention to the upcoming presidential debates and the final weeks of the campaign, the Obama Administration is poised to release some far-reaching regulations, which will have a significant effect on the health care marketplace, including a final rule on the new Medicare payment law and some changes intended to help shore up the health insurance Exchanges established under President Obama’s signature health care law.

Highlights of some of the most significant regulatory actions still to come in the final months of the Obama Administration are provided below.

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CMS provides clinicians flexibility under MACRA but retains 2017 start date for first performance period

Posted by Anne Phelps, Principal, US Health Care Regulatory Leader, Deloitte & Touche LLP and Daniel Esquibel, Deloitte Advisory Senior Manager, Deloitte & Touche LLP on September 9, 2016

In a blog post late Thursday, September 8, 2016, Centers for Medicare & Medicaid Services (CMS) Administrator Andy Slavitt announced two new options for participation in the Merit-based Incentive Payment System (MIPS) that are intended to give clinicians more flexibility to participate in the Quality Payment Program (QPP) under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Notably, the blog post states that the first performance period will still begin on January 1, 2017.

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CMS proposes Chronic Care Management rule changes to increase access and reduce administrative burden

Posted by Steve Burrill, Partner, National Health Care Providers Advisory Leader, Deloitte & Touche LLP and Ryan Haggerty, Deloitte Advisory senior manager, Deloitte & Touche LLP on August 31, 2016

On Friday July 15, 2016, the Centers for Medicare and Medicaid Services (CMS) released its Proposed Rule for the Calendar Year 2017 Medicare Physician Fee Schedule, which outlines changes to Chronic Care Management (CCM). These changes are significant and seek to provide increased reimbursement for patients that require greater levels of medical decision making, attempts to reduce administrative burden, while also aligning CCM more closely to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).1,2

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MACRA payment reforms: The journey is long, but the start date is fast approaching

Posted by Anne Phelps, principal, US Health Care Regulatory Leader, Deloitte & Touche LLP

As we move into the second half of 2016, preparing for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) may take up a lot more time than even the most forward-thinking health care stakeholders expected when they first started to learn about this new law. And for those who have continued to think of MACRA as “just the Doc Fix”–well, the lift might be even heavier.

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CMS releases comprehensive MACRA rules: New law poised to shape payment and delivery reform in the future

US Supreme Court building

Posted by Anne Phelps, Principal, US Health Care Regulatory Leader, Deloitte & Touche LLP, and Daniel Esquibel, Senior Manager, Deloitte & Touche LLP on April 28, 2016.

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) fundamentally changes how physicians and other clinicians are reimbursed under the Medicare Physician Fee Schedule (PFS) and establishes new incentives that will drive payment and delivery reform efforts across the health care payor mix. The law will allow clinicians to develop new care models and encourages new collaborations between plans and hospitals to enter into new payment and delivery models. Importantly, the law was passed with overwhelming bipartisan support and continues to enjoy strong support from Republicans and Democrats in Congress, all but ensuring its continued implementation regardless of the outcome of the November elections.

The Administration this week issued its first major regulation under MACRA: late in the afternoon of April 27, 2016, the Centers for Medicare and Medicaid Services (CMS) released the long-awaited proposed rule1 on the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the law. Taken together, CMS is now referring to the two payment tracks as the Quality Payment Program (QPP).

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