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About This BlogThe SW Health Law Checkup is written by the attorneys of Snell & Wilmer to provide their insight on an array of regulatory and compliance matters related to federal and state fraud and abuse laws and regulations, reimbursement, credentialing and employment of providers, joint ventures and physician-entity integration, best practices in compensation and contracting, value-based purchasing and contracting with providers.
The Medicare Access and CHIP Reauthorization Act (“MACRA”) Final Rule published late last year implements CMS’ new payment approach for physicians and other Medicare Part B eligible clinicians under the Merit-Based Incentive Payment System (“MIPS”) and looks to steer clinicians towards more “at risk” advanced alternative payment models (“Advanced APMs”). In light of some Congressional concerns on MIPS’ potential negative impact on small physician groups, the Final Rule softened some of the initial timeframes for MIPS implementation. In addition, the Final Rule proposed a new “ACO Track 1+” model that would qualify as Advanced APM, which some providers hope will turn out to be that ACO in the “goldilocks zone” – not too much, not too little, but just the right balance of shared savings and risk. Last week, CMS issued some new guidance regarding the ACO Track 1+ model and promised to provide additional details in the coming months. CMS helps (or hopes) to ease into MIPS As we noted in our prior blog post on the MACRA Proposed Rule, MIPS represents the consolidation of three CMS reporting programs: Physician Quality Reporting System, the Value-Based Modifier Program, and Meaningful … Continue reading
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