The Physician-Focused Technical Advisory Committee (PTAC) is
accepting comments until October 14, 2016, on a draft Request for
Proposals (RFP) for physician-focused payment models (PFPMs) and
draft guidance on characteristic of payment models likely to be
recommended by PTAC.
Draft RFP: The draft RFP indicates that any
individual or organization may submit a proposal. PTAC is proposing
to require a letter of intent to be submitted at least 30 days
prior to the proposal, a page limit of 20 pages (although
appendices for additional information are allowed and do not count
towards the page limit) and the proposal would need to be submitted
at least 14 weeks in advanced of a PTAC public meeting. Submitters
would be required to provide an overview of the model and a
narrative describing how the payment model meets the PFPM criteria proposed by the Centers for Medicare
and Medicaid Services.
PTAC states they plan on providing public education sessions and
informational materials, such as webinars and FAQs, regarding the
requirements of the RFP and the proposal review process. PTAC will
also make available technical papers on topics such as accessing
Characteristics of Payment Models Likely to be
Recommended by PTAC: PTAC also released for comment a draft
guidance as to the kinds of payment models that are more likely to
receive favorable recommendations. While in general the document
reflects many of the big picture concepts found in the CMS's
proposed criteria of PFPMs, the document also provides more
practical guidance. For example, the document states that
"PTAC will be unlikely to recommend a proposed PFPM if the
only change it makes is to give a physician the ability to bill for
a single type of service that is not currently eligible for payment
under the Physician Fee Schedule." It also indicates that if a
proposed payment model impacts both physicians and hospitals,
"the PTAC will be more likely to recommend the model as a PFPM
if a substantial portion of the payment supports services that are
delivered or ordered by physicians."
The draft guidance document can be downloaded
reported by McDermottPlus, PTAC recently announced that they
anticipate accepting PFPM proposals beginning December 1, 2016.
Established by the Medicare Access and CHIP Reauthorization Act
of 2015 (MACRA), PTAC is tasked with providing comments and
recommendations to CMS on physician payment models. The Committee
includes 11 members who are nationally recognized for their
expertise in physician-focused payment models and related delivery
of care. More information on PTAC is available on their
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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