This Week – February 18, 2017

This Week in Washington, D.C.

  • Important Dates for ACG Members: Know Your Meaningful Use Dates
  • ACA Repeal Watch: House Republicans Release “Repeal and Replace” Blueprint
  • IRS Updates Policy on Health Coverage Mandate
  • MACRA Tidbit for the Week: How is your MIPS Quality score actually calculated?

From ACG Practice Management Committee Chair, Michael S. Morelli, MD, CPE, FACG

Important Dates for ACG Members: Know Your Meaningful Use Dates

February 28, 2017: Reconsideration forms for the 2017 Payment cut based on the 2015 EHR reporting period are due February 28, 2017.

The deadline for Eligible Professionals (EPs) to submit Reconsideration forms for the 2017 payment adjustment—based on the 2015 EHR reporting period—is February 28, 2017. No applications will be accepted after the deadline.

Please visit the CMS website to find the EP Reconsideration Application. Complete this application if you received a letter from CMS stating that you are subject to the 2017 Medicare EHR payment cut, and you believe this payment adjustment is in error.

For more guidance on completing the application, you may review the EP Reconsideration Instructions.

March 13, 2017: 2016 Meaningful Use Reporting Attestation Period

CMS announced that the attestation period for the 2016 reporting year is now open for those ACG members who have participated in the 2016 Medicare Meaningful Use Program.  The attestation period will end on March 13th.  Providers must attest by the deadline to avoid a 2018 payment adjustment.

CMS has released attestation worksheets as a guide to prepare for reporting for 2016 Meaningful Use attestation.  Providers can log their Meaningful Use measures for each objective in the worksheet and use it as a reference when attesting for the Medicare 2016 Meaningful Use Program in CMS’ Registration and Attestation System.

From ACG National Affairs Committee Chair, Whitfield L. Knapple, MD, FACG

ACA Repeal Watch: House Republicans Release “Repeal and Replace” Blueprint

This week, U.S. House Republicans released a “policy brief” in advance of the Presidents’ Day congressional recess, outlining a replacement plan for the Patient Protection and Affordable Care Act (known as the ACA). This 18-page blueprint states that House Republicans will soon advance repeal and replace legislation that is designed to:

  • Provide relief during the transition period, including waiving the individual mandate as well as the employer mandate to provide coverage.
  • Provide a “Universal Health Care Tax Credit.”  The credit is “advanceable and refundable,” universal for all citizens or qualified aliens not offered other qualifying insurance, age-rated, and available for dependent children up to age 26.
  • Eliminate ACA tax provisions, including the tax on health insurance premiums, taxes related to prescription drugs, the tax on medical devices, the increased expense threshold for deducting medical expenses.
  • Reform Medicaid with a “per capita allotment” (block grant) and repeals the ACA’s Medicaid expansion, with a transition period of continued enhanced federal payments.
  • Utilize “state innovation grants” to improve insurance markets & more: Read the full blog here.

IRS Updates Policy on Health Coverage Mandate

The Internal Revenue Service (IRS) released a statement indicating that it will not be checking the required taxpayer attestation of having health insurance coverage on tax forms.  According to the IRS, the agency put in place system changes that would reject tax returns during processing in instances where the taxpayer didn’t provide information related to health coverage.  However, the Jan. 20, 2017, executive order directed federal agencies to exercise authority and discretion available to them to reduce potential burdens.  Thus, the IRS has decided to continue accepting returns in instances where a taxpayer does not indicate coverage status.  Provisions in the ACA law must be changed by the Congress, and taxpayers remain required to follow the law and pay what they may owe‎.  It is unclear at this time how the IRS will enforce these provisions.

How is your MIPS Quality score actually calculated?

Since the Quality category represents 60% of your total MIPS score, it is important to know what you need to do in order to get the most of your score for this category.  Let’s walk through an example of how the points are allotted from each measure that you report.

An ACG member reports MIPS Quality Measure #113, “Colorectal Cancer (CRC) Screening” via Medicare reimbursement claims forms.

First, the member must make sure that data is submitted on at least 50% of applicable patients (the denominator).  This is what CMS means by “data completeness.”  For measure #113, this is 50% of the Medicare Part B fee for patients aged 50 to 75 years for whom the member provided care for during the reporting period.

A “data completeness” note:  ACG members will receive the minimum number of points for this measure if this minimum level of data completeness is unmet, and/or if the number of patients on which the measure reports is less than 20.  The minimum number of points for CY 2017 is 3 points.

Otherwise, benchmarks based on historical performance scores will be used to determine the maximum number of points available.  Your performance score will be compared to this “benchmark.” (perhaps have the “read more” link here?)

These benchmarks are then assigned to a decile, and the total number of points that can be achieved will be based on the decile in which a physician’s performance rate is found.  On the quality reporting program website, the deciles for the CRC screening measure are available for download.  Deciles range from “3” to “10” for 2017.

Using the same example, the ACG member would have achieved a performance score of 75% in 2017.  This means that 75% of all patients in the dominator were also confirmed to have received a CRC screening, and met the data completeness as well as the minimum case number.  The 2017 benchmark results place a 75% performance score in decile 6 (decile 6’s range is 64.41 – 75.4%).

Thus, the provider would receive roughly 6 points for that measure.

TIP: Know the measure’s specifications!  It is important to stress that ACG members should study the denominator for each measure and understand what exactly needs to be performed in order to meet the measure’s requirements.  For example, measure #113 does not require you to actually perform the screening, but instead, to confirm that the patient has been screened for colorectal cancer.  Since 60% of your total MIPS comes from the Quality category, you need to understand how to maximize your points.  ACG is here to help.