MACRA: The Burden of Proof

MACRA:  The Burden of Proof

by Carol Monaco

The Centers for Medicare and Medicaid Services has released a 2,398-page final rule implementing what is likely the most complex clinician payment program in Medicare’s history, known as the Quality Payment Program, born out of the Medicare Access & CHIP Reauthorization Act of 2015 or MACRA.

As MACRA is implemented, the hope of financial stability and administrative relief for physicians treating Medicare patients may be short-lived.

If past is prologue, physicians should prepare themselves for years of payment system revisions, modifications, and amendments that go well beyond 2019 when the Quality Payment Program’s first payment adjustments go into effect.


Carol Monaco, an independent writer who is an expert in health policy and regulatory issues, produced an in-depth analysis of the CMS proposed rule to implement MACRA and the likely implications on private physician practice.

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MACRA: The Burden of Proof

by Carol Monaco

The Centers for Medicare and Medicaid Services is in the process of implementing what is likely the most complex clinician payment program in Medicare’s history, known as the Quality Payment Program, born out of the Medicare Access & CHIP Reauthorization Act of 2015.

As MACRA is implemented, the hope of financial stability and administrative relief may be short-lived.

If past is prologue, physicians should prepare themselves for years of payment system revisions, modifications, and amendments that go well beyond 2019 when the Quality Payment Program’s first payment adjustments go into effect. Also, by November 1 when the Quality Payment Program is expected to be finalized, stakeholders will find out whether CMS has decided to substantially dial back the numerous performance requirements, complex composite scorings, confusing financial risk calculations, and tight implementation timelines spelled out in the 962-page proposed rule.


Carol Monaco, an independent writer who is an expert in health policy and regulatory issues, takes a deep dive into the likely implications of the CMS proposed rule to implement MACRA.

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