EBG Commentary

MACRA Physician Payment Reform: Time to Take Stock of What Is Working and What Changes Are Needed

Health Care and Life Sciences Client Alert

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”), which the Centers for Medicare & Medicaid Services ("CMS") has implemented through the Quality Payment Program (“QPP”). MACRA allows Medicare Part B clinicians to take part in the QPP in one of two ways: through the Merit-Based Incentive Payment System or through Advanced Alternative Payment Models. The first performance period is currently underway for clinicians subject to the Medicare Part B physician payment reforms enacted under MACRA.

CMS published a proposed rule addressing continued implementation of the QPP for the second performance year, starting in 2018. Comments on this new proposed rule are due next week. Therefore, now is the time for stakeholders to take stock of how things are working so far and to consider if any changes should be suggested to the Trump administration regarding how it should approach the QPP in future years. Ideas for simplifying the policies, reducing the burden of QPP on clinicians, and ensuring that QPP requirements do not interfere with patient care should be submitted to CMS by August 21, 2017.

See below to download the full Alert in PDF format.

Lauren Farruggia, a Summer Associate (not admitted to the practice of law) in Epstein Becker Green’s Washington, DC, office, contributed to the preparation of this Client Alert.