Skip to Content

Filter by:

Washington Highlights

CMS Releases RFI for MACRA Implementation

October 2, 2015—The Centers for Medicare and Medicaid Services (CMS) Sept. 28 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 with a 30-day comment period.

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA, P.L. 114-10) replaced the sustainable growth rate (SGR) formula with a program that uses quality components as a driver of reimbursement rates. Beginning Jan. 1, 2019, physician payments will be driven by either transitioning to APM or participating in MIPS, a consolidated pay-for-performance program. 

In the RFI, CMS solicited stakeholder feedback on numerous issues, including appropriate identification and exclusions of MIPS eligible professionals (EP).  An EP’s composite score will be based on the four performance categories, which include: quality, resource use, clinical practice improvement activities, and meaningful use of certified EHR technology. CMS is also seeking feedback on an appropriate methodology to evaluate and assess these performance categories and whether composite score information should be publicly reported on Physician Compare.

CMS also seeks feedback on how APM eligibility should be defined. Currently, an eligible APM entity is: (1) Use of certified EHR technology, (2) bears a nominal financial risk, (3) specific payment and/or patient threshold requirements. However, CMS believes further criteria needs to be established on how to determine who is eligible for incentive payments for APM participation.

Additionally, CMS requests feedback on the development of Physician-Focused Payment Models (PFPM). This will be an opportunity for providers to submit PFPMs to the newly established “Physician-focused Payment Model Technical Advisory Committee” that will review and provide comments and recommendations to the Secretary of Health and Human Services.  CMS is looking to establish specific criteria for the committee to use and assess in order to promote robust and well-developed proposals to facilitate implementation of PFPMs.

Comments are due Nov. 02, 2015.  CMS will publish the proposed rule in the spring of 2016 and the final rule is expected in November 2016. 


Ivy Baer, J.D., M.P.H.
Senior Director and Regulatory Counsel
Telephone: 202-828-0499


envelope on a green background

Subscribe to Washington Highlights

RSS icon

Subscribe to RSS

Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

Past Issues

For More Information

Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806