Recognizing the complexity of the MACRA legislation, the Association expressed appreciation that CMS considered a variety of comments from a diverse set of stakeholders in developing the proposed rule.  In their detailed comments, they emphasize that some of the complexities in the proposed rule will lead to many significant changes and implications for eligible clinicians.  EHRA urged CMS to take every possible step to dramatically simplify requirements in the final rule and to develop provider-focused communications to reduce complexity.

When it comes to alternative payment models (APMs), organizations often ask “is it better to be a Medicare Shared Savings Program (MSSP) Track 1 Accountable Care Organization (ACO) or a Patient-Centered Medical Home (PCMH)?”

Typically, the answer depends on a few factors:  organizational goals, level of readiness to adopt new delivery models, and the mix of public and private payer incentive programs.

Going forward, however, the newest factor that organizations must consider is how they want to be scored under the incentive programs created by the Medicare Access and CHIP Reauthorization Act (MACRA).  As the Centers for Medicare and Medicaid Services (CMS) prepares to release the proposed rule for MACRA, the agency has made it clear that not all organizations participating in APMs will be considered “eligible” for purposes of the law’s APM incentive program.  The statute requires that eligible APMs, those which qualify for the APM bonus payment, have the following characteristics:

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