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CMS Issues Proposed Rule for an Extensive Change in Physician Payment Policies

Apr 28, 2016

On Wednesday, your Academy received a prepublication of a proposed rule issued by the Centers for Medicare & Medicaid Services (CMS) that signifies the most extensive change in physician payment policies in the last two decades.

The proposed rule is for the Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models. Your Academy is working diligently to read and synthesize the information and determine how it will impact physiatry.

“Health care is undergoing significant reform, and this proposed rule is indicative of the changes we as physiatrists, and as physicians who are part of a larger medical community, are about to experience. Pay attention and get involved,” encouraged Greg Worsowicz, MD, president of AAPM&R. “Also, utilize the Academy as a resource during these times of change. Together, we can ensure the physiatric approach to care is represented and thriving in the future of health care.”

What we do know right now is that the proposed rule:

  • Establishes the Merit-Based Incentive Payment System (MIPS), a new program for certain Medicare-participating practitioners.
  • MIPS would consolidate components of 3 existing programs:
  1. The Physician Quality Reporting System (PQRS)
  2. The Physician Value-based Payment Modifier (VM)
  3. The Medicare Electronic Health Record (EHR) Incentive Program for eligible professionals (EPs)
  • MIPS would continue the focus on quality, resource use, and use of certified EHR technology in a cohesive program that avoids redundancies.
  • Sunsets payment adjustments under the current PQRS, VM, and the Medicare EHR Incentive Program for EPs. Components of these 3 programs would be carried forward into the new MIPS program.
  • Establishes incentives for participation in certain alternative payment models (APMs), supporting the Administration’s goals of moving more fee for-service payments into APMs that focus on better care, smarter spending, and healthier people.
  • Includes proposed criteria for use by the Physician-Focused Payment Model Technical Advisory Committee (PTAC) in making comments and recommendations to the Secretary on physician-focused payment models (PFPMs).
  • Changes the name of the Medicare EHR Incentive Program, also known as “Meaningful Use”, to Advancing Care Information.
  • The compliance period is January 1 – December 31, 2017 and will determine payment bonuses and penalties for 2019. 

Proposed rules allow for a 60 day comment period. This gives AAPM&R an opportunity to continue to provide feedback in order to improve the final regulations. The final rule will be published by CMS in the fall of 2016.

Your Academy is committed to supporting you and the entire specialty through these changes. We will be engaging Academy member volunteers and key stakeholders during the comment period.

Contact healthpolicy@aapmr.org with any questions or comments.