October 27, 2021

Volume XI, Number 300

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October 27, 2021

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Making Sense of the MACRA Final Rule Part 2 of 3: Alternative payment Models

Many observers view the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) as a game changer for the delivery and payment of health care services.

On Oct. 14, 2016 the Centers for Medicare & Medicaid Services (CMS) published a final rule with comment period (final rule) implementing the bipartisan MACRA legislation. The rule finalizes regulations to replace the Medicare sustainable growth rate (SGR) formula. Under the new system, fee-for-service payment rates under the Medicare Physician Fee Schedule (MPFS) are linked to care delivery, quality and value-based variables.

MACRA’s implementation begins in earnest on Jan. 1, 2017. This article is part of a three-part series that examines various legal, operational and strategic considerations associated with MACRA. This article is based on the unpublished version of the final rule submitted to the Office of Management and Budget on Oct. 14, 2016.

Specifically, this article focuses on Alternative Payment Models (APM) under the “Quality Payment Program” (QPP), as established by MACRA and implemented by the final rule. Separate articles in this series examine:

  • Essential elements of the QPP, including its policy objectives, participation alternatives, and operational details related to the program, and
  • Details of the Merit Based Payment Incentive System (MIPS) participation vehicle.

This article addresses:

To view or download a pdf of the full alert, please click here.

You can read part one of this series here.

© Polsinelli PC, Polsinelli LLP in CaliforniaNational Law Review, Volume VI, Number 316
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About this Author

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Janice Anderson offers a unique perspective to health care clients that is based on her extensive clinical and health care operational background (including serving on the senior executive team for a large regional health system for 14 years). She focuses her practice on corporate health care and transactional law, as well as mergers and acquisitions, hospital/physician and other joint ventures, physician relationships and contracting, and compliance.

Her areas of emphasis include:

 

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Ken Briggs, Polsinelli Law Firm, Healthcare Attorney
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Ken Briggs helps all entities engaged in health care make sense of the modern business and legal environment. He focuses on finding comprehensive solutions to address health care regulatory and transactional needs for providers, facilities, and their service partners. Ken works with clients through the life-cycle of their projects from inception to operational fine-tuning. These matters commonly involve: clinical integration/alignment initiatives, corporate transactions, and managed care arrangements. 

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Bruce Johnson, Health Care Organization Attorney, Polsinelli Law FIrm
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Bruce Johnson assists clients with a strategic, forward-thinking and pragmatic approach. He brings more than 25 years of legal and management consulting experience to his health care organization clients. Bruce assists hospitals, medical groups, academic practice plans and other health care enterprises in crafting effective relationships to promote business objectives while taking into account strategic, compensation, business operations, compliance, and other issues in today’s changing payment and delivery environments.

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Marissa Urban, Fraud, Health Care, Polsinelli Law Firm
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Marissa Urban assists clients with a business-minded and practical approach. Marissa applies experience in fraud and abuse, mergers and acquisitions, regulatory compliance, and Federal Health Care Programs to promote client business objectives and legal compliance. Her years of experience in the pharmaceutical industry representing pharmaceutical manufacturers, pharmacy benefits managers, and pharmacies in strategic business development, mergers and acquisitions, and regulatory compliance provide experience-based insight for all types of health care entities. Marissa assists pharmacy...

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