This Week – December 3, 2016
This Week in Washington, D.C.
- Important Date for ACG Members: December 7 is the deadline to appeal 2015 PQRS and VM review
- ACG Meets with FDA Commissioner and Leaders
- Rep. Tom Price, MD and Seema Verma to lead HHS and CMS
- MACRA Tidbit for the Week: How CMS Determines Your MIPS Score in 2017- two basic examples
From ACG National Affairs Committee Chair, Whitfield L. Knapple, MD, FACG
Important Date for ACG Members: December 7 is the deadline to appeal 2015 PQRS and VM review
ACG members have until December 7 to contest potential payment penalties associated with CY 2015 Physician Quality Reporting System (PQRS) and/or the Value Modifier (VM) reporting. The deadline to file this informal review was originally November 30, but CMS extended this deadline by one week.
According to CMS, ACG members should have been notified by mail, or your respective PQRS feedback reports, if you are subject to 2017 Medicare reimbursement cuts by successfully participating in PQRS. You can determine whether you are subject to VM penalties or bonuses via your Quality and Resource Use Reports (QRURs).
ACG members are encouraged to submit a request for an informal review even if you are unsure about your status. Please note that a successful PQRS review will trigger an automatic review of related VM penalties. However, program officials say the safest course is to file requests for review of both PQRS and VM data.
ACG Meets with FDA Commissioner and Leaders
On November 18th, ACG FDA Related Matters Committee Chair, Tedd Cain, MD FACG, participated in a Stakeholder Listening Session with the FDA Commissioner Robert Califf and other FDA leaders. Dr. Cain was invited to speak, and conveyed some issues important to GI clinicians, including:
- Biosimilars: How will the FDA compare and review the safety of two biosimilars for the same innovator product? The FDA only compares the innovator product to a biosimilar. The Agency does not compare biosimilar vs. biosimilar.
- Endoscope reprocessing and safety and the 510(k) device approval process: How will the FDA assure and monitor the safety of endoscopes, as well as when devices are repaired by third party contractors? The FDA strives to balance innovation with safety. The FDA is working with device manufacturers on the safety of products, as well as hospital systems and third party manufacturers on the importance of reporting safety problems and uniform standards.
- PPIs and patient safety: How should private practicing GI physicians answer questions from patients and primary care physicians? The FDA continues to review this issue while balancing the risk/benefit of prescribing PPIs to patients.
The FDA expressed its appreciation for hearing from gastroenterologists in private practice and on the front line of providing care, and hopes to continue working with the ACG. ACG will continue to update members on this partnership.
Please also visit the ACG’s FDA safety alerts and updates website for new information impacting your practice and patients.
Rep. Tom Price, MD and Seema Verma to lead HHS and CMS
This week, President-elect Donald Trump selected Rep. Tom Price, MD (R-GA) to serve as the Secretary for the Department of Health and Human Services (HHS). President-elect Trump has also chosen Seema Verma, a Medicaid health policy consultant, as the Centers for Medicare and Medicaid Services (CMS) Administrator.
Some facts about Dr. Price and Ms. Verma important to ACG members and GI: read the full blog here.
How CMS Determines Your MIPS Score in 2017- two basic examples
By now, ACG members may know about the various MIPS categories, the requirements for each category, the minimum points you need to avoid a payment cut in 2019, etc. How does this translate into day-to-day practice? In the final rule, CMS provides a few scenarios of how Medicare will calculate your 2017 MIPS score.
These scenarios highlight the key takeaway: any attempt to participate in MIPS in 2017 will avoid a payment cut in 2019.
Example 1: The Solo GI Practitioner
For quality scoring, the solo GI physician does the minimum and submits 1 quality measure instead of the required 6 measures.
Quality category is 60% of the final MIPS score. The maximum score a solo MIPS eligible clinician can earn in this category is 60 points (10 points per measure). Under CMS’ finalized scoring approach for 2017, CMS allows all MIPS eligible clinicians to receive a 3 point floor per measure in the quality performance category if the clinician makes some sort of attempt to participate in MIPS… even if that’s just 1 measure for 1 patient. Under this scenario, the physician receives the 3 point floor for the one measure submitted.
The MIPS eligible clinician’s total quality performance category score is 3 (3/total possible points of 60 points) x 60 = 3.
For the improvement activities, the solo physician reports 1 “medium” weighted improvement activity.
The improvement activities performance category score is weighted as 15% of the final score. There are a list of 90+ activities you can choose from, and each activity has a different weight. The MIPS eligible clinician that is a solo practitioner who reports one “medium activity” equals 20 out of the 40 possible points, or 50%, for the improvement activities performance category score.
In this example, the solo GI physician’s improvement activities performance category score is 7.50 (20/40 x 15 = 7.50).
Please note: Different improvement activities scoring rules apply to a solo practitioner (or small group) than to groups of 16 or more clinicians. A solo practitioner who performs one “medium-weighted” activity receives 20 out of 40 potential points in the improvement activities performance category score, and one who performs one high-weighted activity receives 40 out of 40 of the improvement activities performance category score.
Advancing Care Information
For the advancing care information category, the solo GI physician submits the required elements for the “base score” in this performance category. The base score is 50% of the Advancing Care Information category score.
The Advancing Care Information performance category represents 25% of the final score.
In this scenario, the eligible clinician would receive an Advancing Care Information score of 12.5. (50% x 25).
TOTAL MIPS SCORE
The GI solo practitioner’s total MIPS score is 23 Points (3 +7.5+12.5).
This is above CMS’ 2017 performance threshold of 3 points, so the solo physician would not receive a payment cut in 2019, but instead, would be eligible for a potential bonus payment.
Side note: ACG is committed to reducing regulatory burdens for GI practices. We have heard about the significant financial and administrative burdens Meaningful Use (now Advancing Care Information) causes practices. While ACG is not recommending this, please note that in the scenario above, the solo GI clinician could avoid a payment cut in 2019 even by not participating in the Advancing Care Information category. However, it is unclear whether this holds true for the 2018 reporting year.
Example 2: A group with 20 MIPS eligible clinicians
A physician in a group of 20 is part of a practice that is reporting MIPS measures as a group practice.
The group chooses not to submit quality measures.
Quality category is 60% of the final MIPS score. The maximum score a group of 16+ MIPS eligible clinicians can earn in this category is 70 points. CMS allows a 3 point floor per submitted measure in the quality performance category and would automatically calculate an “all-cause hospital readmissions” population-based measure in the Quality Performance category, if the group participates in MIPS and meets the required 200 cases threshold. This is applicable to the group of 16+ clinicians reporting as a group. So the group would have 1 default measure in this performance category.
The group would receive 2.58 points for the Quality performance category. (3/70 quality performance category score x 60 = 2.58)
The group reports only one “high activity.”
The improvement activities performance category score is weighted as 15% of the final MIPS score.
For improvement activities scoring for groups of more than 15 clinicians, all groups who perform one “medium activity” receive 10 out of 40 points for the improvement activities score, and those who perform each “high activity” receive 20 points.
The group would receive an Improvement Activities score of 7.5. (20/40 improvement activities performance category score x 15 = 7.5)
Advancing Care Information
The group decides not to report Advancing Care Information measure.
The Advancing Care Information performance category represent 25% of the total MIPS score.
The group would receive an Advancing Care Information score of 0.
TOTAL MIPS SCORE
The eligible clinician’s group’s total MIPS score is 10.1 points. (2.58 + 7.5 + 0).
This is above CMS’ 2017 performance threshold of 3. Clinicians in the group would not receive a payment cut in 2019, but instead, would be eligible for a potential bonus payment.
Please note: If a group of 16 or more did not report information in any of the MIPS performance categories, then the readmission measure would not be scored. A group will never have a final score based on the readmission measure alone.