On May 9, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule addressing the implementation of physician payment reforms included in the Medicare Access and CHIP Reauthorization Act of 2015 (“MACRA”). The proposed rule outlines the CMS framework for the Merit-Based Incentive Payment System (“MIPS”) and physician participation in Advanced Alternative Payment Models (“Advanced APMs”), two programs that intend to shift Medicare physician payments toward payments for value over volume.

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