The Centers for Medicare & Medicaid Services (CMS) has finalized sweeping reforms of the Medicare physician fee schedule (MPFS) update framework, as mandated by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Beginning in 2017, physicians can choose one of two tracks within its “Quality Payment Program” to determine their MPFS update: reporting under the Merit-based Incentive Payment System (MIPS) or participation in an Advanced Alternative Payment Model (APM). A physician’s 2019 MPFS payment update (positive or negative) is based on action in 2017 – leaving little time to digest and prepare for the new framework before the system kicks in January 1, 2017. In order to give physicians and other affected clinicians additional flexibility going into 2017, CMS adopted several “transition” policies that will allow physicians to “pick their pace of participation” and report fewer quality measures, or report for a partial year and still avoid a negative payment adjustment in 2019, and possibly qualify for a positive adjustment.
While CMS transition policies are intended to help physicians avoid payment cuts in the first year of the program, these policies add to the complexity of the regulations. Read more about the major provisions of the final rule’s new payment framework and significant changes from the proposed rule in our Reed Smith Client Alert here.