Calfee, Halter & Griswold LLPCMS Announces New Advanced Alternative Payment Model Options

November 1, 2016
Some good news for practitioners affected by the Medicare Access and CHIP Reauthorization Act (MACRA): the Centers for Medicare & Medicaid Services (CMS) announced that it is expanding the list of eligible Advanced Alternative Payment Models (APMs) in which practitioners may participate.  Prior to CMS’ announcement, the list of available qualified Advanced APMs was limited.  This is important for those clinicians who are not participating in an APM that would be exempt (or who are participating in an APM that previously would not have been exempt) from the Merit Based Incentive System (MIPS) and, accordingly, would fall into the MIPS track of MACRA with all of the attendant obligations. In 2017, under the Quality Payment Program, practitioners will be able to earn a five percent incentive payment through sufficient participation in the following Advanced APMs: • Comprehensive ESRD Care Model (Large Dialysis Organization (LDO) arrangement) • Comprehensive ESRD Care Model (non-LDO arrangement) • Comprehensive Primary Care Plus (CPC+) • Medicare Shared Savings Program ACOs - Track 2 • Medicare Shared Savings Program ACOs - Track 3 • Next Generation Accountable Care Organization (ACO)  Model • Oncology Care Model (two-sided risk arrangement) In 2018, CMS expects that practitioners will be able to earn the five percent incentive payment through participating in the following Advanced APMs: • ACO Track 1+ • New voluntary bundled payment model • Comprehensive Care for Joint Replacement Payment Model (Certified Electronic Health Record Technology (CEHRT) track) • Advancing Care Coordination through Episode Payment Models Track 1 (CEHRT track) In addition, CMS announced that it expects to reopen applications for new practices in the CPC+ model and new participants in the Next Generation ACO model for the 2018 performance year. CMS states that it will continue to revise these lists and add more Advanced APM options as more models are proposed and developed and expects that a significant portion of participating physicians will earn incentive payments under the Advanced APMs. This is an encouraging sign that CMS will work with the provider community and consider practitioner participation in existing shared savings models as it implements MACRA.