- 2-208 Washington Update Drew Voytal, MPA Associate Director MGMA Government Affairs Agenda Political and legislative environment Federal physician payment landscape Other Trending topics MGMA Advocacy Priority: Regulatory Relief Q&A - - - 2 - Legislative Watch List Political and Legislative Environment What s happening now in Congress - Opioid efforts - Drug pricing and transparency - Government budget expires Sept. 0 Latent health policy issues - Entitlement reform - Repeal and replace ACA - Stabilize individual health insurance markets 208 Midterm elections on Nov. 6 - - - 4 - VA MISSION Act of 208 Congress passed bipartisan legislation to fix VA Choice program following a recent government watchdog report itemizes administrative burdens in VA Choice program Combines the VA s myriad community programs into the new Community Care Program. Creates prompt payment standards to reimburse community providers within 45 days for clean paper claims and 0 days for clean electronic claims. Removes 0-day/40-mile requirement for veterans care in the community. Requires the VA Secretary to develop an education program to inform veterans and VA providers about veterans health care options. Local VA medical facilities will serve as the clinic that coordinates all services outside the VA healthcare system. Federal Physician Payment Landscape REMAINDER OF 208 AND PROPOSED 209-5 - - 6 -
MIPS Policies: 208 versus 209 POLICY 208 209 (PROPOSED) PENALT Y OR BONUS +/- 5% +/- 7% Quality and cost: full calendar year Quality and cost: full calendar year REPORTING PERIOD ACI and IA: any 90 days Promoting Interoperability (ACI) and IA: any 90 days Quality: 50% Quality: 45% Promoting Interoperability (ACI): 25% Promoting Interoperability (ACI): 25% CATEGORY WEIGHTS Improvement Activities: 5% Improvement Activities: 5% Cost: 0% Cost: 5% SMALL PRACTICE BONUS 5 points 5 points Payment adjustment In 2020 2 0 - -2-208 MIPS Payment Adjustments 70 points Additional Adjustment Factor 5 points Performance Threshold 0 0 5 20 25 0 5 40 45 50 55 60 65 69 70 75 80 85 90 95 00 ECs and groups assigned final score of 0-00 points based on performance. Final score compared to performance thresholds set by CMS each year. COMPLEX PATIENT BONUS 5 points 5 points $90,000 Medicare charges or $90,000 Medicare charges or LOW VOLUME THRESHOLD 200 patients 200 patients or 200 covered services Clinicians or groups can opt-in if they meet or exceed one or two, but not all, of LV threshold criteria. -4-5 -6 points -5% reduction Scores above performance threshold result in a bonus; scores below threshold get a penalty. CEHRT EDITION 204 or 205 205 Final MIPS score in 208: 0-00 points - 7 - - 8-209 MIPS Payment Adjustments (PROPOSED) 7 6 5 7.5 points 0 points 80 points -7% reduction Performance Threshold Additional Adjustment Factor 4 Payment 2 Adjustment 0 20 0 40 50 60 70 80 90 00 0 In 202 - -2 ECs and groups assigned final score of (%) - 0-00 points based on performance. -4 Final score compared to performance -5 thresholds set by CMS each year. -6 Scores above performance threshold -7 result in a bonus; scores below threshold get a penalty. -8-9 - - 0-208 Advanced APMs MSSP Tracks 2 & and the new Track + * Next Generation ACOs Comprehensive Primary Care Plus (CPC+) Comprehensive ESRD Care - 2-sided risk! Oncology Care Model - 2-sided risk! Comp Care for Joint Replacement (CEHRT track) *! = not currently accepting new applicants * = New opportunity in 208 NEW APM BUNDLED PAYM ENTS FOR CARE IMPROVEMENT (BPCI) ADVANCED First cohort of participants will start participation in the model on October, 208. The model performance period will run through December, 202 and a second application opportunity will open in January 2020. CMS BPCI Advanced Website 209 Medicare Physician Fee Schedule and MIPS Regulatory Timeline JULY 2, 208 Proposed Rule Published SEPT. 2, 208 Comments Due NOV., 208 Final Rule Published JAN., 209 Effective Date of New Rules We re here to help! MGMA resources will help members understand the impact on practices. Nov. 208: MGMA will release a detailed analysis of final regulations affecting 209 payment and quality reporting rules Dec. 208: MGMA Government Affairs will host a member-benefit webinar Proposed 209 Key Quality Policies in PFS KEY 209 MIPS AND APMS PROPOSALS Clinicians who fall below the low-volume threshold may be able to opt-in to the MIPS program and receive a payment adjustment. Cost measures would count toward 5% of the MIPS final score an increase from 0% in 208. 205 Clinicians and groups would be required to use 205-certified EHR technology. Group practices would be able to submit quality measure data using multiple data submission mechanisms, such as an EHR and registry. APM CMS proposes no new Advanced APMs. Only 60,000 to 25,000 eligible clinicians are expected to become qualifying APM participants, meaning they are exempt from MIPS and eligible for a 5% bonus. In aggregate, APM bonuses are expected to total about $600- $800 million for the 202 payment year. Access the full member-benefit analysis here. - - - 2-2
Proposed 209 Key Policies in PFS MEDICARE EVALUATION AND MANAGEMENT (E & M) Payment: Collapses levels 2-5 into one, single level for new vs. established patients Creates add-ons for certain visits Reduces payment when modifier 25 is used Documentation: Require documentation only to level 2 CONVERSION FACTORS CMS estimates the 209 Medicare PFS conversion factor will be $6.046 The 209 Anesthesia conversion factor is estimated to be $22.2986 Access the full member-benefit analysis here. MIPS/APMs Physician Practice Action Steps Assess performance under past reporting programs Evaluate vendor readiness & costs (ask about 205 CEHRT!) Protect your practice against a MIPS penalty Determine your 208 MIPS goal; establish a reporting strategy Comply with deadlines (hardship exception, CAHPS for MIPS, MSSP, etc.) Analyze data at year-end; hone final reporting strategy Leverage MGMA resources to educate yourself, your physicians and staff - - - 4 - MGMA Resources Washington Connection (link) Subscribe to receive our weekly e-newsletter with breaking updates and everything you need to know from our nation s capital. Other Trending Topics Speak directly with MGMA Government Affairs experts We would like to hear from you! 202.29.450 govaff@mgma.org Dedicated member e-groups (link) For instance, you can discuss MIPS and APMs with,400 MGMA peers and MGMA Government Affairs on the Medicare Value- Based Payment Reform e-group. - 5 - MGMA Stat Poll on Prior Authorization Excessive prior authorization requirements negatively impact our healthcare system. Disrupts continuity of care Interferes with physician-patient relationship Increases administrative burden and cost January 208 Provider/Plan Joint Statement on Prior Authorization Reduce the number of clinicians subject to PA requirements based on their performance, adherence to evidence-based medical practices, or participation in valuebased agreements. Regularly review the services and medications that require PA and eliminate requirements for therapies that no longer warrant them. Improve channels of communications between plans, providers, and patients to minimize care delays and ensure clarity on PA requirements, rationale, and changes. Protect continuity of care for patients who are on an ongoing, active treatment or a stable treatment regimen when changes in coverage, plans or PA requirements. Accelerate industry adoption of national electronic standards for PA and improve transparency of formulary information and coverage restrictions at the point-of-care. - 7 - - 8 -
New Medicare Cards SOCIAL SECURITY NUMBER REMOVAL INITIATIVE (SSNRI) Starting April 208, CMA will: Assign 50 million Medicare Beneficiary Identifier s in the initial enumeration (60 million active/90 million decease/archived) and each new beneficiary Generate a new unique MBI for a Medicare beneficiary whose identity has been compromised Medicare claims can use old HICN until Jan. 2020 Today s Security Environment Practices have now adopted EHRs (75%+) Focus of technology has been on meeting govt reporting requirements (Meaningful Use/QPP), not on HIPAA Security Wannacry/Petya/Allscripts attacks make front page news Orangeworm targeting MRI & X-ray machines Patients increasingly worried about losing their sensitive information SEE APPENDIX FOR NEW MEDICARE CARD CHECKLIST SEE APPENDIX FOR MGMA CYBERSECURITY CHECKLIST - 9-207 - 20 - MGMA Advocacy in 208 ISSUES THAT SET THE STAGE MGMA Advocacy Priority REGULATORY RELIEF Administrative costs in the U.S. healthcare system: $00 billion+ 5% OF ALL HEALTHCARE EXPENDITURES Per year, what practices in four common specialties spend on quality reporting: 785 hours per physician $5.4 billion Amount of practices that stated their group was being evaluated on quality measures that were not clinically relevant: 206 Health Affairs study of MGMA member practices 75% 206 Health Affairs study of MGMA member practices - 2 - - 22 - MGMA 208 Regulatory Relief Survey MGMA Advocacy at Work for Practices SPEAK UP FOR MEDICAL PRACTICES! MGMA Government Affairs is researching the impact of federal government rules and requirements on your practice. Your participation will make a difference by guiding MGMA's advocacy efforts in Washington on important issues facing medical group practices. The findings of this survey will be presented and discussed at MGMA8 The Annual Conference. Access the survey here. MGMA ADVOCACY IN 208 MGMA continuously voices voices medical medical group group practice practice opposition opposition to Medicare to reimbursement Medicare reimbursement cuts. For 208, cuts. we are For focusing 208, on: we are focusing on: Preserving the in-office ancillary exception under the Stark law Stopping the sequester cuts to Medicare Medical liability reform Making MIPS simpler and more predictable Visit our Contact Congress Portal and lend your voice. REGULATORY RELIEF MGMA to HHS: reduce excessive Reduce excessive federal federal mandates and one-size-fits all mandates and one-size-fits regulations. all regulations; Support high-quality, to HHS support high-quality, cost-effective care delivery. Patients over Paperwork initiative with CMS Cut the Red Tape summit with HHS Medicare Red Tape Relief Project with House W&M committee Red Tape Roundtable with House W&M committee Visit MGMA.com/regrelief to learn more. - 2 - - 24-4
MGMA Government Affairs ADVOCACY FEEDBACK LOOP Questions? Washington Update presentations Washington Connection newsletter MGMA Healthcare Guiding Principles Government Affairs Council (GAC) Drew Voytal, MPA Associate Director BOSTON SEPT. 0 OCT. Member-benefit resources Access to GA experts Dedicated Member Communities Grassroots advocacy Collaboration with state MGMAs Advocacy statements and letters Discussions with Congress Coalition and consensus building with industry partners Calls and Meetings with CMS/HHS staff MGMA Government Affairs dvoytal@mgma.org 202.29.450 MGMA.org @DrewVoytal Featuring MGMA Government Affairs sessions: Regulatory Relief Forum Washington Update Health IT Policy Update - 26 - New Medicare Cards KEY PRACTICE CHECKLIST ITEMS APPENDIX - 28 - CONDUCT PATIENT OUTREACH Educate your patients (posters, flyers) Remind patients to protect their new Medicare number and only share it with trusted providers GET READY TO USE THE NEW MBI FORMAT Talk/test with your PMS vendor and ensure systems and workflow can accommodate HICNs and MBIs Ask billers them about their MBI preparations Ensure access to the MAC portal to obtain a patient s MBI starting in June 208 ACCESS THE MGMA NEW MEDICARE CARD MEMBER RESOURCE Today s Security Environment CHECKLIST TO PROTECT YOUR PRACTICE. CONDUCT a complete HIPAA Security Risk Assessment 2. KEEP computer operating systems and antivirus software up-to-date. ENCRYPT all files and systems that contain patient information 4. DEPLOY strong user authentication 5. ENSURE that your business associates are protecting your data 6. REQUIRE training for all practice staff 7. INSTRUCT staff not to open emails/attachments/links from unfamiliar senders 8. BACK UP patient data (offsite) 9. RUN periodic system tests 0. CONSIDER cyber insurance - 29-5