RFI on Medicare Merit-Based Incentive Payment System & Alternative Payment Models

The U.S. Centers for Medicare & Medicaid Services (CMS) has just issued a “Request for Information (RFI) Regarding Implementation of the Merit-Based Incentive Payment System (MIPS), Promotion of Alternative Payment Models (APMs), and Incentive Payments for Participation in Eligible Alternative Payment Models” (80 Fed. Reg. 59102, 10/1/15).  The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA; Pub. L. 114-10, 4/16/15) repealed the sustainable growth rate procedure for updating the physician fee schedule, and created a new reimbursement system to be based on the MIPS.  The MACRA also consolidated aspects of the Physician Quality Reporting System, Value Based Payment Modifier, and Electronic Health Records (EHR) Incentive Program into the MIPS, as well as exempts eligible professionals from potential MIPS-based reimbursement cuts by participating in an APM.  The CMS RIF seeks input on numerous MIPS aspects, including quality performance, resource use performance, clinical practice improvement activities performance, meaningful use of certified EHR technology performance, and performance standards.  For APMs, the RIF seeks input on what type of entity qualifies as an APM and criteria for assessing recommendations for “Physician-Focused Payment Models.”  Electronic and written comments should be received by 5pm, Monday, November 2, 2015.  For additional information, see 80 Fed. Reg. 59102, 10/1/15.