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Moghbel N, Ryu B, Cabot PJ, Ratsch A, Steadman KJ

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of this proposed rule proposes to revise 423.160(a)(5) to specify that prescriptions written for a beneficiary in a long-term care (LTC) facility would not be included in determining CMS EPCS Program compliance until January 1, 2028, and that compliance actions against prescribers who do not meet the compliance threshold based on prescriptions written for a beneficiary in a LTC facility would commence on or after January 1, 2028

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Billing practitioners who are not MIPS eligible clinicians (as defined at 42 CFR 414.1305) would not be required to report the MVP in order to furnish and bill for APCM services