On Friday, October 14, 2016, the Centers for Medicare and Medicaid Services (CMS) issued its Final Rule with Comment, implementing the Quality Payment Program (QPP) delineated in the Medicare Access and Chip Reauthorization Act of 2015 (MACRA). The QPP is designed to reward delivery of high-quality patient care through two programs: Advanced Alternative Payment Methods … Continue Reading
Beginning in January 2017, primary care physicians and their practices (PCPs) will be able to participate in a multi-payer payment reform and care delivery transformation aimed at strengthening primary care. Dubbed the Comprehensive Primary Care Plus (CPC+) initiative, the recently unveiled primary care medical home model is CMS’s latest effort to encourage value-based payment methodology, … Continue Reading
The Food and Drug Administration (FDA) requested comments on March 4 regarding definitions and possible regulations governing medical device refurbishers, reprocessors, and other third parties. Medical device manufacturers have the duty, under 21 C.F.R. Part 820, to provide instructions to third parties that may service or install their products. However, manufacturers may not be able … Continue Reading
Among other reasons, CMS may terminate an ACO from participating in the Medicare Shared Savings Program if the ACO avoids “patients at risk” to reduce the likelihood of increasing costs to the ACO. The Affordable Care Act, however, does not define which patients are at risk. In the recently release proposed ACO rule, CMS proposes … Continue Reading
Although the Affordable Care Act allows hospitals employing physicians and other non-physician professionals such as advance practice nurses, physician assistants and nurse practitioners, to be eligible providers for an ACO, only primary care services provided by primary care physicians matter in determining the beneficiaries that would be assigned to an ACO. And only those ACOs … Continue Reading