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CMS Releases QPP Proposed Rule

Tuesday, June 27, 2017   (0 Comments)
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June 22, ASCA Government Affairs Update


On Tuesday, the Centers for Medicare & Medicaid Services (CMS) released their proposed rule for updates to the Quality Payment Program (QPP) established under the Medicare Access and CHIP Reauthorization Act (MACRA). MACRA replaced the Sustainable Growth Rate (SGR) formula as the mechanism for determining physicians’ Medicare payments with two new, value-based reimbursement systems: the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). This year’s proposed rule is meant to further clarify requirements and reporting deadlines that were proposed in the initial QPP rule released last April.


Early analysis of the 1000-plus page proposed rule for 2018 has focused on the desire by CMS to slow MACRA/QPP implementation, easing reporting requirements and giving physicians greater flexibility and time to comply with new policies. Under the new rule, physicians with up to $90,000 in Medicare Part B charges or less than 200 unique Medicare patients will be exempt from MIPS (previously $30,000 in charges or 100 unique patients). Additionally, MIPS physicians can continue using the 2014 Edition certified EHR technology (CEHRT), though CMS encourages switching to one of 74 products certified under 2015 Edition CEHRT. No ASC-specific CEHRT exists at this time.


Finally, the proposed rule included an expected provision allowing solo practitioners and/or small physician groups (10 or fewer clinicians) to combine into “virtual groups.” These groups would then collectively report and be assessed under MIPS requirements, though they do not have to share the same geographic location or specialty.


More information about any of the issues above can be found in the CMS QPP fact sheet. Interested parties can also read the official press release announcing the proposed rule. Please contact Alex Taira at with any questions.

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