Oct. 27, 2016
Issue SpotlightPhysician voice shapes Medicare pay reform final rule
An AMA Viewpoints post by AMA President Andrew W. Gurman, MD
With the issuance of its final rule on MACRA, CMS has created a new Medicare payment system called the Quality Payment Program (QPP).
There is still work to be done to improve the QPP, but it appears that we are off to a strong start. CMS' revisions will allow for a reasonably paced progression into the program so that physician practices can learn and adjust over time.
Some key elements of the proposed rule that CMS changed based on our recommendations are:
- A transition period and avoiding the QPP penalty. The proposed rule stated that physicians would have to successfully report in all four Merit-based Incentive Payment System (MIPS) categories to avoid a negative payment adjustment. The AMA advocated for a transition year with lower reporting burdens. In the final rule, the only physicians who will experience a negative 4 percent penalty in 2019, the first year of the program, are those who choose to report no data in 2017.
Participating in one of four options under "Pick Your Pace" will help you avoid penalties. At the very least, if you choose to report for only one patient on just one quality measure, one improvement activity, or the four required Advancing Care Information (ACI) measures you will avoid a negative payment adjustment.
We recommended that CMS create a transition period to allow enough time for physicians to prepare for the QPP. The final rule establishes a 90-day reporting period, a significant change over the proposed rule's full calendar-year requirement for most reporting. If you report for at least 90 continuous days in 2017, you will be eligible for a positive payment adjustment. This revision allows you to start later so that you will have more time to prepare your practice.
- An increase in the low-volume threshold. Initially, the proposed rule set the threshold for exemption for QPP participation for physicians with less than $10,000 in Medicare payments and fewer than 100 Medicare patients per year.
The AMA recommended increasing the threshold to $30,000 or fewer than 100 Medicare patients and CMS opted for that baseline in the final rule, estimating the provision will exempt 32.5 percent of eligible clinicians from MIPS reporting.
- A reduction in the programwide reporting burden. One of the leading causes of our frustration as physicians is Medicare's overwhelming reporting burden.
For example, under the ACI category that replaces the electronic health record (EHR) Meaningful Use program, the number of required reporting measures was cut from 11 in the proposed rule to four in 2017 and five thereafter. Previous quality reporting requirements were reduced as well.
These are only a few of the changes that CMS made in the final rule based on our recommendations (complete AMA summaries of changes and the final rule). As a physician who will be undergoing this transition at the same time as you, I want to do whatever I can to make sure we are all prepared, educated and set up to succeed under this new program.
There will be further developments as other provisions of MACRA are implemented and we will continue to work with CMS to make sure the QPP is positioned to work for all physicians.
Read more at AMA Wire®.
National UpdateCMS launches long-term effort to improve physician engagement
Last week, the Centers for Medicare and Medicaid Services (CMS) announced a new initiative to improve the physician experience with the Medicare program. This long-term effort seeks to take a comprehensive look at how physicians interface with the Medicare program's new payment models. The hope is that this will enable a ground-up review of the administrative burdens faced by physician practices and improve physician satisfaction as administrative processes are redesigned or eliminated.
CMS marked the beginning of this effort with an 18-month pilot program to reduce medical review for certain physicians while continuing to protect program integrity. Under the program, physicians practicing within specified Advanced Alternative Payment Models will be relieved of some scrutiny under certain medical review programs. The AMA will actively engage CMS as this program moves forward.
Visit the CMS website to access a fact sheet and a list of frequently asked questions for more information about the pilot.
In honor of Veterans Day, the Joining Forces initiative is hosting its 2016 Wellness Week on Nov. 7 – 11. The AMA was an early supporter of efforts to engage physicians to improve the health of service members, veterans and their families. This will take the form of daily webinars aimed at health professionals during Wellness Week.
Each webinar is worth one continuing medical education credit and will be held from noon to 1 p.m. EDT daily:
- Nov. 7 — Joining Forces to address suicide in the military and veterans
- Nov. 8 — Caring for caregivers
- Nov. 9 — Pain management: Nuances for the military and veteran patient population
- Nov. 10 — The deployment life cycle of the military family: Implications for healthcare providers
- Nov. 11 — What veterans want their healthcare providers to know and how academic medical centers can contribute
The AMA continues to work with the U.S. Department of Veterans Affairs to ensure that veterans receive timely access to high-quality care through the Veterans Choice Program. Read more about the AMA's efforts to support veterans' health.Deadline approaches for seeking review of potential Medicare payment penalties
Late last month CMS posted information on its website that physicians can consult to determine whether they will be subject to 2017 Medicare payment penalties associated with the Physician Quality Reporting System (PQRS) and the Value Modifier. As reported in the most recent Advocacy Update, practices that are concerned about the findings in their report(s) have until Nov. 30 to file for an informal review of their data.
The penalties in question stem from policies in effect prior to the enactment of the Medicare Access and CHIP Reauthorization Act (MACRA). Failure to successfully complete required PQRS reporting will result in a 2 percent penalty. Value Modifier penalties can range from 1 percent to 4 percent, depending on the size of the practice and its performance on cost and quality measures. PQRS penalties will be communicated to physicians by mail as well as in the PQRS feedback reports posted on the CMS website. Value Modifier penalties and bonuses can be found in Quality and Resource Use Reports posted on the website only.
Those who have questions, even if they are uncertain about penalty status, are urged to submit a request for informal review. Although in most cases a successful PQRS review will trigger an automatic review of related Value Modifier penalties, program officials say the safest course is to file requests for review of both PQRS and VM data.
For more information, visit the CMS website.
State UpdateCigna says it will end prior authorization for MAT
National health insurance carrier Cigna will end the use of prior authorization for medications used to treat opioid use disorder. Cigna said that the new policy will be effective Oct. 15, 2016, and applied throughout the United States. The insurer did say, however, that it "reserves the right to apply quantity limits to MAT medications consistent with generally accepted practices."
The announcement comes on the heels of requests by the New York attorney general to obtain information about the insurer's use of prior authorization. It further complements existing law in New York that prohibits insurers from requiring prior authorization for emergency supplies of medication-assisted treatment (MAT) medications and also removes prior authorization for Medicaid members seeking MAT for opioid dependence. The Medical Society of the State of New York supported the changes in law to remove the restrictions.
Read the agreement with Cigna for more information.
The Richmond County Medical Society and Medical College of Georgia have teamed up to provide new continuing medical education (CME) resources that are free to all physicians – and not just in Georgia. The courses include presentations that:
- Describe the difference between physical dependence and the disease of addiction and treatment of patients who have co-occurring chronic pain syndrome as well as addictive disorders
- Answer questions that address whether depression causes tobacco, alcohol and drug use; and whether the use of drugs that target the brain's reinforcement and mood centers cause depression
- Provide a neuroscientist's perspective and understanding of the science of addiction, how heroin works, why it is so addictive, and what can be done to reclaim those fighting its grasp
- Present the various issues that are unique to addicted physicians as well as diagnostic and treatment approaches to this population. Specific assessments and treatment structures and outcomes for these physicians are also discussed.
For more information about the courses, contact the Medical Association of Georgia Foundation's Lori Murphy.
For more information, and additional state and specialty-specific resources, visit the AMA Task Force to Reduce Opioid Abuse website.
The Interstate Medical Licensure Compact Commission (Commission), the entity charged with administering the Interstate Medical Licensure Compact (Compact), recently met in Kansas to discuss proposed rules, hear public testimony and continue to plan the infrastructure behind the Compact.
The AMA has participated in all meetings and provided feedback on draft rules, and encourages all state medical associations to do the same. Whether your state is a Compact member, or interested in joining the Compact, these meetings provide valuable input as to the Compact's progress, requirements and rules. Track the Commission's progress, read meeting minutes, and provide input through written or public testimony by visiting the Commission website and signing up for listserv alerts. Meeting minutes and other public notices are also available on the Commission's website.
The AMA strongly supports the Compact, and stands ready to assist any medical association interested in pursuing Compact legislation. Contact Kristin Schleiter of the AMA to learn more.
Other NewsNCVHS recommendations reflect AMA advocacy on administrative simplification
In order to reduce administrative burdens and financial waste in the health care system, the Health Insurance Portability and Accountability Act (HIPAA) created standard electronic transactions for use in the exchange of information between providers and health plans.
To ensure that these transactions promote optimal administrative savings, the Affordable Care Act tasked the National Committee on Vital and Health Statistics (NCVHS) to serve as the Review Committee to evaluate the transactions, operating rules and current implementation of the standards and make recommendations for improvement.
On June 16 – 17, 2015, the NCVHS Review Committee convened a hearing to gather industry feedback on the HIPAA-mandated standard transactions. The AMA participated in several panels and submitted extensive recommendations on how the transactions can be improved to help reduce administrative waste. You may access the AMA's slides and written testimony for this hearing.
The NCVHS recently released the Review Committee's report with recommendations to the U.S. Department of Health and Human Services. The Review Committee's report features a significant number of the AMA recommendations that, if implemented, will improve administrative efficiency and reduce burdens and costs for physician practices. Included in the Review Committee's recommendations were the AMA's suggested improvements to the electronic eligibility, prior authorization and remittance advice transactions.
More information on standard electronic transactions and to access other administrative simplification resources is available at the AMA Administrative Simplification Initiatives website.
Under the Affordable Care Act (ACA), patients receiving an advance premium tax credit who do not pay their health insurance premiums enter a 90-day "grace period." During the first month of the grace period, the patient continues to have health insurance coverage, and the patient's health plan will pay claims for services provided during that time.
However, health plans will not extend coverage for the second and third months of the grace period if the patient does not pay his or her premiums in full before the end of the 90-day period. Patients are responsible for paying the entire bill for services provided during that time. Certain states have similar allowances for premium payment grace periods.
Electronic communication of grace period notification can help ensure that physicians and their staff receive this important information in a timely manner. Following strong advocacy from the AMA over the past two years, the Accredited Standards Committee (ASC) X12 — the standards development organization responsible for creating and maintaining standard electronic administrative transactions — recently released a new implementation guide supporting electronic communication of premium payment grace period information.
This electronic transaction includes the capability to notify practices when a patient has paid a premium and is no longer in a grace period. Transmitting grace period information in a computer-readable format minimizes the burdens and costs associated with paper notifications for both physician practices and health plans and represents a win-win for the industry.
The Premium Payment Grace Period Notification (271 version 007030X344) guide is available from ASC X12. To learn more about the ACA grace period, visit the AMA's ACA grace period webpage.
Nov. 21 & Dec. 6: MACRA Educational Webinars
The AMA will host an educational webinar on two different dates to help physicians prepare for the new Medicare Quality Payment Program created by MACRA. Both sessions will cover the same material. Registration is open for the first webinar on Nov. 21, 7 p.m. EST, and the second webinar on Dec. 6, 8 p.m. EST. Physicians and medical society staff are welcome.
Nov. 29: MACRA Educational Webinar for Staff
This AMA-hosted session is for Federation staff and will feature an intense review of MACRA so that they are best prepared to field questions from their members. 1 p.m. EST.
Dec. 1: MACRA Regional Seminar, Atlanta
The Medical Association of Georgia, the Medical Association of Atlanta, the Cobb County Medical Society, and the DeKalb Medical Society invite physicians and medical staff to an educational session to help physicians prepare and understand what the final rule means for their practices and what they need to do as part of the QPP. Cobb Galleria Centre, Two Galleria Parkway, 6:30 p.m. EST. Also available by streaming and webinar. Register.
Dec. 10: MACRA Regional Seminar, San Francisco
The AMA and California Medical Association will host an educational seminar similar to the one held in Atlanta, to be held at the Marriott Marquis, Nob Hill Ballroom, 780 Mission St., 9:30 a.m. PST. Also available by streaming and webinar. Register.