The Centers for Medicare & Medicaid services late today issued a proposed rule implementing key provisions of the new physician payment system required by the Medicare Access and CHIP Reauthorization Act of 2015. Section 101 of MACRA repeals the Medicare sustainable growth rate methodology for updates to the physician fee schedule and requires CMS to establish new physician quality and value-based payment programs that start in 2019. Eligible clinicians will participate in one of two tracks – the default Merit-based Incentive Payment System or alternative payment models. In the rule, CMS proposes most of the requirements of the MIPS for 2019, including performance measures, data submission mechanisms, reporting timeframes, scoring methodology and various administrative processes. As part of the MIPS, the agency proposes to replace electronic health record meaningful use requirements for physicians with a more flexible set of "advancing care information" measures. The rule does not propose parallel changes for hospitals. However, the agency does propose to require that all hospitals, critical access hospitals and physicians attest to three statements that indicate they do not engage in information blocking. CMS also proposes criteria for eligible APMs. Specifically, the agency proposes that an entity that participates in an eligible APM must bear financial risk for any excess Medicare spending over projected expenditures, or be a specified medical home. For 2019 APM incentive payments, eligible models based on financial risk would be Tracks 2 and 3 of the Medicare Shared Savings Program, the Next Generation ACO model, the Comprehensive End-stage Renal Disease Care model, and the two-sided risk model in the Oncology Care program. The newly-announced Comprehensive Primary Care Plus initiative would qualify as a medical home. “We are deeply disappointed by CMS’s narrow definition of alternative payment models, which could have a chilling effect on providers’ ability to experiment with new patient-centered, value-driven payment models,” said AHA Executive Vice President Tom Nickels in a statement. Nickels also noted that the proposed rule “fails to recognize the significant resources and risk assumed by the highly motivated, early adopters of alternative payment models.”  CMS is accepting comments on the proposed rule through June 27. AHA members will receive a Special Bulletin tomorrow with additional information.

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