CMS moves forward with implementation of MACRA, other policy changes in Physician Fee Schedule Update

The Centers for Medicare and Medicaid Services (CMS) on Thursday, November 2, 2017, released final rules on Medicare reimbursement for 2018 that will have significant implications for providers’ margins and drive many provider and payer organizations to revisit their strategic objectives. The final rules for the 2018 performance period under the Quality Payment Program (QPP) of the Medicare Access and CHIP Reauthorization Act (MACRA) and the 2018 Part B Physician Fee Schedule Update include critical details that will have implications for providers related to value-based care, coding compliance, health information technology investments and telehealth services, among other issues.

The final rule for the MACRA QPP 2018 performance period is scheduled for publication in the Federal Register on November 16, 2017, and the final rule on the Part B PFS update is scheduled for publication in the Federal Register on November 15, 2017. Provisions of both rules will take effect January 1, 2018.

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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MACRA repealed the sustainable growth rate (SGR) formula for updates to the Medicare Part B Physician Fee Schedule and sets payment updates for all years in the future.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 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 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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