Saturday, October 3, 2015

Keeping Track of CMS Comment Periods for Labs and for MACRA

CMS currently has four comment periods open, one on 2015 gapfill, one on 2016 proposed gapfill/crosswalks, one on PAMA rulemaking, and one on MACRA's physician payment reforms.


GAPFILL 2015: 
     COMMENT BY OCTOBER 26

On September 25, 2015, CMS released gapfill pricing for CY2015 codes with the results of MAC gapfill pricing efforts.   The webpage is here and the comment period runs to October 26, 2015. 

CROSSWALK/GAPFILL 2016: 
     COMMENT BY OCTOBER 26

On September 25, CMS also released its centrally decided proposed pricing methodologies for new CY2016 lab codes, also with a 30 day comment period.  This is a true comment period; CMS has only offered proposed prices for the 2016 codes and seeks comment.


MACRA: PHYSICIAN PAY INCENTIVES: REQUEST FOR INFORMATION: 
    COMMENT BY NOVEMBER 2 17

On October 1, CMS published a Request for Information on how it will implement MACRA ("SGR Reform") Section 101, which heavily revises physician incentives and penalties based on performanc metrics.   Different sections apply variously to doctors under fee for service and doctors in ACOs.  The RFI is here.  Comments are accepted until November 2, 2015 (extended to November 17, 2015).


PAMA LAB PRICING RULEMAKING: 
     COMMENT BY NOVEMBER 24

On September 25, CMS released PAMA rulemaking.  The comment period runs until November 24, 2015.  See here.