Washington Update Agenda Trending topics Quality Payment Program: Mid-Year Status Report Proposed 2018 Medicare regulations Healthcare Reform Update Q&A 1
Non Discrimination Standards Where did it come from? New regulations rooted in Section 1557 of the ACA Who does it impact? Practices that accept federal $$ from any sources other than solely Medicare Part B, including Parts A or D, Medicaid, or MU incentive payments How do I comply? 1. Formalize and document a language access plan 2. Post a notice of nondiscrimination 3. Include taglines notifying patients that language services are available (should be posted in office, on website and any significant publications ) For more information, visit mgma.org/section1557-3- - 4- Virtual Credit Card/EFT Service Fees What you need to know: Fees can reach up to 5% Payer doesn t have to notify practices of new charges Small payers are NOT excluded HIPAA prohibits unreasonable transaction fees * CMS guidance expected soon Action steps for protecting your practice: 1. Request EFT payment using MGMA s sample letter or by visiting CAQH s EnrollHub 2. Stand firm against fees citing HIPAA regulations 3. Lodge a formal complaint with OCR For more, access MGMA s EFT/ERA Guide 2
Cybersecurity Some hospitals were impacted by WannaCry, but no reports of attacks on physician group practices so far. MGMA has joined HHS-led industry taskforce to prevent future ransomware attacks Even small breaches can cost practices millions & bad PR Action steps for protecting your practice: 1. Be especially vigilant using older or Windows operating systems 2. Conduct a HIPAA security risk assessment 3. Keep operating system and antivirus software up to date 4. Encrypt systems and files that contain patient information 5. Regularly train staff on safe security protocols For more, register for MGMA s cybersecurity webinar and check out our cybersecurity action steps >> Meaningful Use Incentive Payments EHR vendor eclinicalworks to pay $155 million settlement to resolve allegations it misrepresented software capabilities to obtain certification and paid kick-backs According to FAQ, CMS will not audit providers who relied on eclinicalworks software for MU attestation In new report, OIG found 14 out of 100 sampled practices did not comply with MU requirements and received a combined total of $792 million in improper MU payments OIG recommends audits of MU incentive payments - 6-3
PQRS Feedback Reports & QRURs Typically released in September Why should you still care? Comparable metrics to MIPS (though not exact) Will impact 2018 Medicare payments Must submit informal review request by the deadline if there are any inaccuracies, or face a penalty (deadline is typically late Nov or early Dec) - 7- Quality Payment Program: Status Report 4
MIPS Pick your Pace Options for 2017 Pick Your Pace Pick your pace All-in Report some data Definition Report full MIPS data for at least 90 consecutive days (up to a full year) Report 1 or more of the following for at least 90 consecutive days: - More than 1 quality measure - More than 1 improvement activity - More than 4 ACI base measures Test the program Report at least one of the following: 1 quality measure; OR 1 improvement activity; OR 4 ACI base measures Do nothing Report no data Projected 2019 MIPS Payment Adjustments Projected 2019 MIPS Payment Adjustments Payment Adjustment 4% 3% 2% 1% 0% -1% -2% -3% -4% MIPS Performance Threshold Exceptional Performance Threshold 3 70 100 MIPS Score 5
Main Title Category Reverse If you only report 90 days, you could still earn the maximum adjustment there is nothing built into the program that automatically gives a reporter a lower score for 90-day reporting. CATEGORY 1 CATEGORY 2 CATEGORY 3 CMS QPP website -11-2017 MIPS Tips: Improvement Activities 15% of MIPS score scored out of 40 points CMS will not release more detailed activity-level specs Criteria was purposefully kept broad Will feature a simple yes/no attestation Supporting documentation suggested for each activity Only one clinician needs to attest to completing an activity for a group to count it - 12-6
2017 MIPS Tips: Quality 60% of MIPS score scored out of 60-70 points Measure benchmarks can vary by reporting mechanism Bonus points are awarded even if the measure isn t counted as one of the highest scoring six 2017 features a 3-point floor, even if measures fall short of data completeness criteria (can report on 1 patient) Data completeness thresholds are based on proportion of applicable patients, not # of clinicians who report data - 13-2017 MIPS Tips: ACI 25% of MIPS score scored out of 100 points All base measures feature a yes/no attestation or 1- patient denominator Health info exchange and provide patient access measures count as base measures AND are worth 20 points as performance measures You may get bonus credit for improvement activities you intend to report anyway or registry data you were already reporting under MU 7
Potential advantages to group-level MIPS reporting Entire practice gets same MIPS score Must select 1 reporting mechanism per MIPS performance category Must select 6 quality measures for group, but not every clinician has to report data for every measure if data completeness requirements are met Only 1 clinician needs to attest to completing an improvement activity Low threshold for entire group to avoid 2017 penalty Implications for certain exceptions - 15-2017 MIPS Exceptions, Exclusions & Special Scoring ACI Exclusions Hospital-based Non-patient facing Facing significant hardship Can voluntarily send data MIPS-Level Exceptions Brand-new to Medicare Clinician type isn t counted Below low-volume threshold* * Applied at group level if data is reported as a group - 16- IA Special Scoring Cannot voluntarily opt-in Half credit Full credit Non-patient facing PCMHs Small/rural practices MIPS APMs For more, check out MGMA s resource >> 8
Timing of critical 2017 MIPS reporting information Dec. 29: Quality measure benchmarks and specifications April 19: Approved qualified registry list April 26: MIPS eligibility notifications May 25: Approved QCDR list June 28: Technical assistance providers for small/rural practices July 24: Special scoring status (small, rural, HPSA, non-patient facing, & hospital-based clinicians/practices) View all of these at the CMS resource library >> MIPS APM Scoring Standard - 18- What is it? A special scoring mechanism that differs from standard MIPS and rewards APMs for work they are already doing. Who is it for? 1) Advanced APMs that meet the partial QP threshold and elect to participate in MIPS 2) Specifically designated MIPS APMs (ex: MSSP Track 1) How does it work? MIPS score is assessed at the APM Entity level Reporting responsibility varies by category MIPS categories are weighted differently 9
About 10% of clinicians will participate in Advanced APMs in 2017 2017 AAPMs MSSP Tracks 2 & 3 Next Generation ACOs Comprehensive Primary Care Plus Comprehensive ESRD Care (2-sided risk) Oncology Care Model (2-sided risk) Comp Care for Joint Replacement (CEHRT track) About 20% of clinicians are expected to participate in Advanced APMs in 2018 2018 AAPMs MSSP Tracks 2 & 3 and 1+ Next Generation ACOs Comprehensive Primary Care Plus Comprehensive ESRD Care (2-sided risk) Oncology Care Model (2-sided risk) Comp Care for Joint Replacement (CEHRT track)?? Cardiac Rehab Incentive Payment Model?? Advancing Care Coordination through Episode Payment Models (Track 1)?? 10
Physician Practice Action Steps Assess performance under past reporting programs Evaluate vendor readiness & costs Protect yourself against a MIPS penalty Determine your MIPS goal; establish a reporting strategy Comply with deadlines (MSSP, etc.) Analyze data at year-end; hone final reporting strategy Engage in ongoing learning; keep an open mind in 2018+ Check out MGMA s QPP participation checklist >> MGMA Resources MGMA Resources Washington Connection (mgma.com/washington) Weekly e-newsletter with breaking updates and everything you need to know from our nation s capital MACRA/QPP Resource Center (mgma.com/qpp) Your one-stop shop for new resources & information - MACRA FAQs Dedicated MIPS/APMs e-group Get your questions answered and engage in a dialogue with your MGMA peers about all things MACRA 11
MGMA Resources How about a show of hands? How many of you Plan to participate in an Advanced APM? Expect to be excluded from MIPS? Plan to score 3 points to avoid the MIPS penalty? Are going for a MIPS bonus? Are aiming for the exceptional performance bonus? Proposed 2018 Medicare Regulations 12
Pros Delay new CEHRT mandate Offer new facility-based scoring option Raise low-volume threshold Add new ACI exclusions Delay cost category 2017 QPP Proposed Rule Key proposals would Cons Require full-year quality reporting Not add a single new AAPM Raise MIPS threshold to 15 pts Not commit to providing more frequent feedback Still disadvantage small practices MGMA s bottom line: Some key but piecemeal improvements that do little to address fundamental concerns with MIPS and QPP. However, this administration seems open to negotiating improvements & reducing the burden on practices. Key proposals would: 2018 physician fee schedule proposed rule Set a 2018 Medicare PFS CF of $35.9903 Delay appropriate use criteria for advanced imaging services until 2019 Retroactively lower PQRS and MU reporting requirements and reduce the size and scope of Value-Modifier penalties Seek input about opportunities to reduce regulatory burdens on physician practices Solicit comments on reporting lab $$ data Read the proposed rule and fact sheet >> 13
Now what? Check out MGMA s member-exclusive analysis of 2018 Medicare proposals based on the PFS and QPP proposed rules >> MGMA is actively engaged in conversations with stakeholders and federal agencies and plans to submit formal comments on both rules Submit your own comments: 2018 proposed PFS comments are due Sept. 11 2018 QPP proposed rule comments are due Aug 21 Stay tuned for final versions of both rules, expected by Nov. 1 Gearing up for a busy month on Capitol Hill 14
Healthcare Reform AHCA passed House in May but failed in the Senate Unclear if/when long-term repeal will be taken back up Focus has shifted to uncertainty for 2018 Currently 19 counties with no indiv. exchange products Trump admin won t commit to making subsidy payments Insurers threatening to roll back participation & raise premiums due to unpredictability Senate HELP committee will race to create bipartisan legislation that would stabilize exchanges Insurers must sign exchange contracts by Sept. 27 FY 2018 starts Oct. 1 On the docket Various healthcare reauthorization bills including CHIP & community health centers Spending package 12 separate bills Debt limit must raise ceiling or face default What to expect Likely several of these will be combined into larger omnibus package Continuing resolution most likely spending outcomewould continue FY 2017 levels until a long-term agreement can be reached 15
MGMA: Your Voice MGMA: Your voice in Washington Washington In letter, MGMA cited serious concerns with the Housepassed AHCA based on our healthcare reform principles. We will continue to monitor Senate actions and evaluate future drafts against these same core principles. MGMA signs onto letter urging CMS to include MA APMs toward Medicare Advanced APM threshold MGMA calls on CMS to test episode-based cost measures MGMA urges delay of lab reporting under PAMA MGMA calls for delay in EHR certification mandates MGMA demands past-due MIPS eligibility notices 2017 MGMA. All rightsreserved. Questions? Visit: www.mgma.org Email: sfalk@mgma.org 16