OCTOBER 28, 2019

Welcome to the MACRA MIPS/APM Update eNewsletter
Editor: Philip L. Ronning
This issue is sponsored by the National ACO Summit, the National Bundled Payment Summit,
the National Medical Home Summit, and the National MACRA MIPS/APM Summit

CMS Wanted Comments. It Got Close to 29K, Including a Flood From Physical Therapists and Psychologists
As the comment period comes to a close tomorrow on a proposed physician fee schedule, the Centers for Medicare & Medicaid Services (CMS) already got an earful, including letters from physical therapists, psychologists and social workers telling the agency not to cut their Medicare reimbursements. As of this morning, the federal agency received close to 29,000 comments on the proposed regulation that makes changes to the physician fee schedule and updates the Quality Payment Program established under MACRA. The comment period closes at 5 p.m. Friday. The healthcare sector remains in flux as policy, regulation, technology and trends shape the market. FierceHealthcare subscribers rely on our suite of newsletters as their must-read source for the latest news, analysis and data impacting their world. Sign up today to get healthcare news and updates delivered to your inbox and read on the go. Hundreds of comments came from physical therapists, psychologists and social workers who appealed to CMS not to cut their reimbursements so higher payments can be made for evaluation and management (E/M) services included in the proposed rule (PDF). There were several controversial issues in the proposed rule issued in late July to establish 2020 Medicare payment rates and make changes to the physician payment program implemented under MACRA, including the Merit-based Incentive Payment System (MIPS). (FierceHealthcare, September 26, 2019)

Docs Laud E/M Proposal, Blast Pay Cuts in Physician Fee Schedule Rule
As the comment period for the proposed 2020 Medicare Physician Fee Schedule rule drew to a close on Friday night, CMS received over 30,000 comments, including letters from major industry groups commending the agency for proposing to do away with a policy that would collapse evaluation and management (E/M) payment rates. CMS decided in the 2019 Medicare Physician Fee Schedule final rule to consolidate E/M levels 2 through 5 into a single payment rate by 2021 to reduce the administrative burden associated with Medicare documentation requirements. Facing staunch industry criticism, the federal agency proposed earlier this year to walk back on the policy, which many industry groups are now praising. "CMS recognized that its earlier plan for E/M visits would have disrupted care patterns and may have created other unintended consequences. Having the separate codes helps acknowledge the difference in resources in treating patients with more complex care needs," the American Medical Group Association's (AMGA) president and CEO Jerry Penso, MD, MBA, said in a statement. Finalizing the proposal to keep separate E/M payment rates would also avert unintended consequences, such as forcing "medical practices to reduce their Medicare patient volume or limit the medical issues addressed during one office visit due to lower reimbursement rates for more complex visits," MGMA stated in its comments. (RevCycle Intelligence, September 30, 2019)

MACRA, 2 Years Later: 9 Ways to Make it Better
Two years in, the Medicare Access and CHIP Reauthorization Act (MACRA) remains a work in progress, but there are several specific steps Congress can take with MACRA and its Quality Payment Program (QPP) that will help physicians succeed and patients thrive. "The QPP is a complex program that remains challenging for CMS to implement and difficult for physicians to understand," AMA President Barbara McAneny, MD, told the U.S. Senate Finance Committee at a May 8 hearing. "However, the AMA is confident that if Congress, the Centers for Medicare & Medicaid Services, and the medical community continue to work together to improve the program, we can ensure physicians have the opportunity to be successful and provide high value care to patients." To improve MACRA programs, Dr. McAneny prescribed three priorities and six suggested technical adjustments. (America Medical Association, May 2019)

Making MACRA Work for Patients and Physicians
As an ophthalmologist, I treat eye diseases, such as cataracts and glaucoma, which primarily impact our country's oldest Americans. This means that when Medicare payments aren't keeping up with the cost of providing care, specialty practices like mine are the first to notice. Data from the Department of Health and Human Services bear this out: A recent Medicare Trustees Report found that physicians' costs are expected to rise 2.2 percent annually and that current payment levels won't keep up. The report predicts that low reimbursement rates may eventually create an access barrier for beneficiaries. When Congress enacted the Medicare Access and CHIP Reauthorization Act in 2015, the intention was to repeal the flawed Sustainable Growth Rate and provide modest, positive Medicare payment updates. In addition, MACRA created two pathways to earn additional positive adjustments: the Merit-Based Incentive Payment System that would allow physicians to remain in fee-for-service and report on clinically relevant quality measures and activities; and Advanced Alternative Payment Models that would award participants with 5 percent annual bonuses. (Morning Consult, September 24, 2019)

ACC Comments on Programmatic Changes in Proposed 2020 Medicare PFS
The ACC has submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) to address programmatic changes in the proposed 2020 Medicare Physician Fee Schedule, with a particular focus on opportunities for bundled payments, Merit-Based Incentive Payment System (MIPS) Value Pathways, changes to the Quality Payment Program (QPP), Medicare Shared Savings Program, electronic health records and health data, and more. A separate letter addressing pricing aspects of the proposed rule was submitted earlier this month. The letter includes five key requests regarding ongoing implementation of the Quality Payment Program: 1) Continue efforts to prevent the QPP from being an administrative burden on clinicians; 2) Finalize programs that adequately balance flexibility with quality patient care; 3) Provide clinicians with meaningful measures appropriate to the patient population of interest; 4) Provide enough time for the development of novel paths and frameworks to meet QPP performance goals in the following year and years to come; and 5) Continue to eliminate barriers to Alternative Payment Model (APM) participation. (American College of Cardiology, September 25, 2019)

After Delay, CMS Says Physicians Can Expect Payments for Advanced APM Bonuses Soon
After an appeal from nine physician organizations, the Centers for Medicare and Medicaid Services (CMS) says doctors and other healthcare professionals who qualify for an advanced alternative payment model (APM) performance bonus should get their money soon. CMS announced in a fact sheet (PDF) that incentive payments will go out soon to clinicians who earned a performance bonus as part of their participation in advanced APMs in 2017. CMS said it would begin paying the incentive payments, due for the first year of its Quality Payment Program, starting this month. The medical organizations, including the American Medical Association and the American Academy of Family Physicians, sent a letter (PDF) to CMS last month expressing concerns about a long delay in the payment of those performance bonuses. (FierceHealthcare, October 3, 2019)

Operationalizing MACRA QPP MIPS Through the Medical Home

MACRA MIPS/APM Update e-Newsletter is one of a family of free e-Newsletters providing a complimentary video presentation and regularly updated news and key resources on major health care issues such as ACOs, patient safety, pay for performance, bundled payment, readmissions, and Medicaid. To view and subscribe to other e-Newsletters go to healthcareeNewsletters.com.

Keynote: Update on Private Sector ACO Initiatives

Hoangmai H. Pham, MD
Vice President, Provider Alignment Solutions, Anthem; Former Chief Innovation Officer, Center for Medicare and Medicaid Innovation, Centers for Medicare and Medicaid Services, Washington, DC