The Road to Physician Payment Reform: Key Considerations for MIPS and APM Participation

Houston Medical Times July 2016

Helaine I. Fingold, a Senior Counsel in the Health Care and Life Sciences practice, in the firm’s Baltimore office, and Lesley Yeung, an Associate in the Health Care and Life Sciences practice, in the firm’s Washington, DC, office, authored an article in the Houston Medical Times, titled “The Road to Physician Payment Reform: Key Considerations for MIPS and APM Participation.”

Following is an excerpt:

In April 2015, Congress established a new framework for Medicare Part B physician payments through the passage of the Medicare Access and CHIP Reauthorization Act of 2015 (“MACRA”). After consultations with and outreach to clinicians and other stakeholders, in May 2016 the Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule on implementing MACRA’s physician payment reforms. The proposed rule defines how CMS would shift fee-for-service payments that reward physicians for the volume of services delivered to payments that reward physicians based on value and patient outcomes through the “Quality Payment Program” (“QPP”). Over the next few months, CMS will be sorting through submitted public comments, including some expressing concerns that the QPP is too complex and its implementation is proposed to happen too quickly, to determine how it will finalize the initial implementation rules for the QPP. However, clinicians should not wait for the final rule to be published this Fall, but should act now to determine their best options for participating in the various payment pathways established in MACRA.