Help NRHA ensure rural is considered as CMS implements new Medicare programs

By: Alan Morgan | 10/07/15

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CMS recently released a request for information (RFI) regarding the implementation of the Merit-based Incentive Payment System, Promotion of Alternative Payment Models, and Incentive Payments for Participation in Eligible Alternative Payment Models. Essentially, CMS is working on implementing the last of the “doc fixes” that Congress passed in April to repeal the Sustainable Growth Rate (SGR). NRHA needs your help to make sure rural is considered and that the new replacement program works for rural. The RFI is essentially a brief explanation of the program CMS is required to implement, followed by a long list of questions about how it should be implemented. Your response can be answers to these questions or anything else you think CMS should know or consider when they are implementing these programs. There are three major areas discussed:

1. Merit-based Incentive Payment System (MIPS) –  This program must include measures for quality, resource use, clinical practice improvement activities and meaningful use of certified electronic health records. The program is intended to be a streamlined combination of the three existing physician quality programs, with the addition of a measure of clinical practice improvement activities.
2. Alternative Payment Models (APMs) and Physician Focused Payment Models (PFPMs) – There are 5 percent bonuses for providers receiving a significant portion of their revenues from an APM or PFPM (not to mention Secretary Burwell has set Medicare goals of increasing participation in APMs to 30 percent in 2016 and 50 percent by 2018).
3. Technical assistance to small practices with preference to this in health professional shortage areas and rural areas

It is essential that we ensure the specific needs of rural providers and patients are considered in all three of these. For rural to be well-represented, CMS must hear from not only NRHA but from all of you. Email Diane Calmus if you’d like assistance on your response and send your responses to her so they can be included in an NRHA letter. Comments are due Nov. 2 and can be submitted electronically at www.regulations.gov.