The Centers for Medicare and Medicaid Services (CMS) has issued this Request for Information about implementation requirements for the Medicare Access and CHIP Reauthorization Act (MACRA) enacted in April 2015. MACRA repeals the Sustainable Growth Rate (SGR) fee schedule for physician payments for fee-for-service Medicare, replacing it with incremental increases effective immediately (CY2015) through CY2018. Beginning in 2019, physicians would only receive increased Medicare fee-for-service payments either through a new Merit-Based Incentive Payment System that would combine current Medicare incentive payments under the Health Information Technology for Economic and Clinical Health (HITECH) Act for the meaningful use of electronic health records, the Physician Quality Reporting System (PQRS), and the Value-Based Payment Modifier; or through “alternate payment models” (APMs). The APMs listed as examples in the text of MACRA include accountable care organizations and bundled payments. MACRA also authorizes CMS to develop additional Physician-Focused Payment Models (PFPMs).
In addition, MACRA authorizes CMS to enter into contracts with quality improvement organizations, regional extension centers, regional health collaboratives, and other organizations to provide technical assistance on the implementation of MIPS for small practices (defined as practices with 15 and fewer eligible providers) and practices in health professional shortage areas (HPSAs) and medically underserved areas (MUAs), including rural areas. The RFI also seeks comments about how to design and implement this technical assistance.
CMS already had raised several questions about the implementation of MACRA in its proposed rule for the Medicare physician fee schedule for CY 2016. This RFI is an additional pre-regulatory process to request additional public comments on how the MIPS should be designed, and how APMs and PFPMs should be defined. Comments may be submitted electronically on the federal regulations website and are due by November 2, 2015.
CMS also will conduct two nationwide webinars about MACRA and the RFI on October 8 and on October 15. While there is no fee for participating in the webinars, separate registration for each webinar is required.
Ignatius Bau 