News and noteworthy information for October 2016:
- CMS Releases MACRA Final Rule
- Preparing Your Practice for MACRA
- CPT Editorial Panel – Summary of Panel Actions
- Palmetto Draft LCD: Noncovered Services
- Understanding the RUC Survey Instrument
- CMS Announces New Initiative to Improve Physician Experience with Medicare
- Deadline for Seeking Review of Potential Payment Penalties
CMS Releases MACRA Final Rule
On October 14, the Centers for Medicare and Medicaid Services (CMS) issued the final rule implementing the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA was bipartisan legislation signed into law in April 2015 to permanently repeal the Sustainable Growth Rate (SGR), streamline physician quality reporting programs, and provide incentive payments for physician participation in alternative payment models. MACRA sunsets the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier, and the Medicare Electronic Health Record (EHR) Incentive Program and establishes an umbrella Quality Payment Program with two new pathways for payment: 1. Merit-Based Incentive Payment System (MIPS) and 2. Advanced Alternative Payment Models (Advanced APMs). The new Quality Payment Program dramatically changes the way Medicare reimburses more than 600,000 clinicians across the country.
Along with the final rule, CMS also announced a new Quality Payment Program website, which explains the new program and helps clinicians easily identify the measures most meaningful to their practice. ISASS is currently analyzing the final rule and will provide a summary to our members in the coming weeks. The Quality Payment Program takes effect on January 1, 2017 and CMS is accepting public comments on the final rule for the next 60 days at regulations.gov.
For More Information on the Final Rule:
Preparing Your Practice for MACRA
On November 21 and December 6, the American Medical Association (AMA) will host educational webinar sessions to help physicians prepare and understand what the final rule means for their practice. These sessions will cover the same material. Physicians are encouraged to participate in one of the sessions.
Register for the November 21st webinar (7:00 p.m. – 8:00 p.m. EST): https://cc.readytalk.com/r/y70aavsqh5g0&eom
Register for the December 6th webinar (8:00 p.m. – 9:00 p.m. EST): https://cc.readytalk.com/r/j8d0v8kh1qr3&eom
In addition to the educational webinars on November 21 and December 6, the AMA has released new tools and resources to help physicians prepare for MACRA/Quality Payment Program:
- The AMA Payment Model Evaluator is an innovative tool offering initial assessments to physicians so they can determine how their practices will be impacted by MACRA. Developed with the expertise of physicians and input from partners, the tool will give physicians and their staff a brief assessment, as well as relevant educational and actionable resources. Once physicians and medical practice administrators fill out the online questionnaire, they will receive guidance for participating in the MACRA payment model that is best for them. The AMA will continually update the Payment Model Evaluator to respond to regulatory changes and to keep practices up to date throughout the new payment and care delivery reform process. The tool is free to all physicians and their practice administrators.
- The AMA STEPS Forward™ collection of practice improvement strategies has new MACRA-specific tools. Accurate and successful reporting on quality metrics is crucial to the new Medicare payment system, both in the current Physician Quality Reporting System program and under MACRA’s new Quality Payment Programs. Each STEPS Forward module focuses on a specific challenge and offers real-world solutions, steps for implementation, case studies, continuing medical education, and downloadable tools and resources. Physicians and their practice staff can use these to help improve practice efficiency and ultimately enhance patient care, physician satisfaction and practice sustainability. The full collection, which now includes 42 modules, has a variety of tools that will help physicians and their practices, including:
The AMA also launched a ReachMD podcast series titled Inside Medicare’s New Payment System. Andy Slavitt, acting administrator of CMS, Dr. Gurman, AMA staff experts, and others are featured on the series, which will include five episodes to help physicians be informed on upcoming Medicare changes.
CPT Editorial Panel – Summary of Panel Actions
On October 28, the CPT Editorial Panel released its summary of Panel actions from the September/October meeting in Austin, TX. The Panel approved the addition of a definition for partial vertebral corpectomy to the guidelines in the Anterior or Anterolateral Approach for Extradural Exploration/Decompression, Lateral Extracavitary Approach for Extradural Exploration/Decompression, and Excision, Anterior or Anterolateral Approach, Intraspinal Lesion subsections in the Nervous System/Spine and Spinal Cord Section of CPT. The Panel also approved the creation of a new Category I code to report bone marrow aspiration for purposes of bone grafting in spine surgery. The full report of Panel actions can be accessed here.
Palmetto Draft LCD: Noncovered Services
On October 3, Palmetto GBA, the Medicare Administrative Contractor covering North Carolina, South Carolina, Virginia, and West Virginia issued a draft local coverage determination (LCD) for Noncovered Services other than CPT Category III Noncovered Services (DL36954). It has been confirmed that Palmetto mistakenly placed CPT code 27279 (Arthrodesis, sacroiliac joint, percutaneous or minimally invasive (indirect visualization), with image guidance, includes obtaining bone graft when performed, and placement of transfixing device) on the list of noncovered services. This error will be corrected in the final LCD.
Understanding the RUC Survey Instrument
On October 12, the American Medical Association (AMA) released an educational video explaining the Relative Value Scale Update Committee (RUC) survey process. The goal of the 13-minute video is to educate potential RUC survey respondents on the purpose and mechanics of the RUC survey process as well as inform potential respondents on how to correctly and efficiently complete a RUC survey. ISASS appointed an advisor and alternate advisor to the RUC when it joined the AMA House of Delegates in June 2014 and actively participates in the RUC survey process related to surgical spine issues. If you are selected to complete a RUC survey, it is vital that you complete the survey to help determine the time and intensity of a procedure in order to appropriately assign a value.
CMS Announces New Initiative to Improve Physician Experience with Medicare
On October 13, the Centers for Medicare & Medicaid Services (CMS) announced a new initiative to improve the clinician experience with the Medicare program. As delivery system reforms from the Affordable Care Act and the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) are implemented, this new long-term effort aims to reshape the physician experience by reviewing regulations and policies to minimize administrative tasks and seeks other input to improve clinician satisfaction.
Acting CMS Administrator, Andy Slavitt is appointing Dr. Shantanu Agrawal to lead the initiative, which will cover documentation requirements and existing physician interactions with CMS, among other aspects of provider experiences. To ensure CMS is hearing from physicians on the ground, each of the ten CMS regional offices will oversee local meetings to take input from physician practices within the next six months and regular meetings thereafter. These local meetings will result in a report with targeted recommendations to the CMS Administrator in 2017. Three of CMS’ regional Chief Medical Officers – Dr. Barbara Connors in Philadelphia, Dr. Ashby Wolfe in San Francisco, and Dr. Richard Wild in Atlanta – have agreed to serve as regional directors of this initiative.
The initiative’s first action is the launch of an 18-month pilot program to reduce medical review for certain physicians. Under the program, providers practicing within specified Advanced Alternative Payment Models (APMs) will be relieved of some scrutiny under certain medical review programs. After the results of the pilot are analyzed, CMS will consider expansion along various dimensions including additional Advanced APMs, specialties, and provider types.
Deadline for Seeking Review of Potential Payment Penalties
In late September, the Centers for Medicare and Medicaid Services (CMS) posted information that physicians can consult to determine whether they will be subject to 2017 payment penalties associated with the Physician Quality Reporting System (PQRS) and the Value Modifier (VM). Practices that have concerns about the findings in their report(s) have until November 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% penalty. Value Modifier penalties can range from 1% to 4% 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 web site. Value Modifier penalties and bonuses can be found in Quality and Resource Use Reports (QRURs) posted on the web site only.
Physicians 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 VM penalties, program officials say the safest course is to file requests for review of both PQRS and VM data.