On July 8, 2015, the Centers for Medicare & Medicaid Services (“CMS”) issued the Medicare Physician Fee Schedule Proposed Rule (“MPFS Proposed Rule”) for calendar year 2016, which includes a broad request for comments on provisions included in the Medicare Access and CHIP Reauthorization Act of 2015 (“MACRA”) related to the implementation of physician payment reforms following the repeal of the sustainable growth rate (“SGR”) formula.

The elimination of the SGR and the push towards pay-for-performance programs and provider participation in quality merit-based incentive payment systems (“MIPS”) and alternative payment models (“APMs”) presents new opportunities and challenges not only for physicians, but also for the entire health care industry, including hospitals, other providers, suppliers, drug/device manufacturers and vendors, professional societies, and private payers. For all of these entities, there will be no shortage of complex and evolving rules and requirements to understand and act upon as the health care delivery and payment landscape continues to change in the coming years.

Stakeholders should consider now how to engage with CMS in the implementation process for the complex payment reforms included in MACRA, and whether to submit comments to the MPFS Proposed Rule. Comments are due to CMS by 5 p.m. on September 8, 2015.