More than 3,000 comments were received prior to the June 27 submission deadline for the proposed rule implementing the Quality Payment Program, which, under federal law, replaces the Sustainable Growth Rate methodology for updating physician payments under Medicare. The proposed rule, which carries a 60-day comment period, offers detail on how the Centers for Medicare & Medicaid Services (CMS) plans to operate the Merit-based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs). The vast majority of Medicare-participating physicians are expected to fall under the MIPS, with a smaller number of clinicians reimbursed under risk-based APMs. Groups like the American Medical Association, American Academy of Family Physicians, the Medical Group Management Association, and the American Hospital Association are all urging CMS to delay the start date of the Quality Payment Program. Under the current plan, MIPS-participating physicians face Medicare Part B payment adjustments of up to 4% upwards and downwards, based on performance scores beginning in 2019. Adjustments climb to 9% beginning in 2022.