07/06/2016

APMA Submits Comments on MACRA Implementation

APMA submitted comments to CMS on June 27 addressing concerns with the proposed rule implementing the new Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Passed in 2015, MACRA repeals the Medicare Sustainable Growth Rate (SGR), replaces it with MIPS for certain Medicare-enrolled practitioners, including podiatrists, and establishes incentives for participation in certain APMs. 

MIPS consolidates three existing programs:

• Physician Quality Reporting System (PQRS)
• Physician Value-Based Payment Modifier
• the Medicare Electronic Health Record (EHR) Incentive Payment Program

In its letter to CMS, APMA addressed its significant concern with the short time frame physicians will have to prepare for MIPS and APMs. The proposed rule calls for the implementation to start on January 1, 2017, leaving physicians with only months, or even weeks after the final rule is issued, to prepare for a major change in how Medicare reimbursement and incentives are issued. To that end, APMA recommended that CMS delay implementing this massive new payment program until later in 2017 or even later, and shorten the performance period for eligible professionals (EPs) participating in MIPS.  

APMA will continue to provide resources and training to members. The June 27 letter is available on APMA's Comment Letters page. For more information, visit APMA’s MACRA Resource Page, or contact APMA’s Health Policy and Practice Department.