This Week – July 2, 2016
This Week in Washington, D.C.
- ACG Submits MACRA Comments: Helping independent GI practices successfully participate in new Medicare payment system
- Update on CA Bill Seeking to Waive Patient Cost-Sharing for Therapeutic and Diagnostic Screening Colonoscopy
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) establishes the Merit-Based Incentive Payment System (MIPS), a new reimbursement system for many ACG members. This proposed rule also establishes incentives for participation in certain alternative payment models (APMs).
ACG submitted its formal comments to CMS this week focusing on the theme of lowering practice management burdens and reducing reporting thresholds in MIPS and APMs. Lowering practice management burdens and continuing this uphill battle against Medicare reimbursement cuts continues to be ACG’s top public policy goals this year. Among recommendations to lower administrative headaches in the comments, ACG urged CMS to lower quality reporting thresholds, encourage the use of registries to meet the various MIPS categories, allowing CME to factor into MIPS scoring, and also significantly changing the Advancing Care Information (formerly known as “Meaningful Use”) requirements.
Key Topics and Data in ACG’s Comments to CMS
- Cost Burden: ACG has found that CMS underestimates the costs and time it takes to participate in Medicare quality reporting. CMS says participating in the Quality Component will require an estimated 6-18 hours per eligible provider and an estimated $400-1,290 of administrative fees borne by the practice. The Advancing Care Information Component will require an additional estimated 4 hours in time and $182 in costs. Finally, reporting Clinical Practice Improvement Activities will require another 3 hours of practice time and an additional $182 in practice costs. This totals an estimated 25 hours and $1,654 per eligible provider. These estimates also do not reflect the costs associated with health information technology investments and annual upkeep (see below).
- Time Burden: In the 2016 Medicare Physician Feel Schedule Final regulation, the CMS time burdens estimates associated with participating in the Physician Quality Reporting System are 5-16 hours per eligible provider. In 2016, providers must report at least 9 measures, covering at least 3 of the NQS domains, and must report each measure for at least 50 percent of the provider’s eligible patients. While CMS reduces the measures required for the Quality Component of MIPS from 9 measures to 6 measures, CMS also significantly increases the percentage of patients required for each measure, from 50% to 80-90% of eligible patients. In doing so, CMS appears to understand this additional burden borne by providers in these proposed changes. The time per measure under the Quality Component of MIPS (18 hours/6 measures = 3 hours per measure) is almost double the estimated time to report quality measures under PQRS (16 hours/9 measures =1.7 hours per measure). This will have a significant impact on GI practices across the country, especially since the Quality Component of MIPS (which all providers must participate in 2017) comprises of 50% of the total MIPS score in 2019, and then 45% of the provider’s total MIPS score in 2020.
- CME Should Count: In addition to their busy practices, ACG members are required to earn continuing medication education credits as well as maintenance of certification (MOC). While ACG continues to fight on your behalf to change onerous and costly MOC requirements, ACG urged CMS that members should receive Clinical Practice Improvement Activities credit for participating in CME hours.
- EHR Headaches: ACG previously compared CMS’ estimated time and cost data for participating in the Medicare Electronic Health Record Incentive Program to actual feedback from members to gauge the regulatory impact by practice size. The College found that CMS woefully underestimates the time it takes to participate in Meaningful Use as well as the annual health IT maintenance costs. ACG’s feedback is also consistent with recently published peer reviewed medical literature on the costs and time burdens associated with participating in the Medicare Electronic Health Record Incentive Program. When releasing Meaningful Use regulations, CMS estimated that it will cost GI practices $50,000 per provider for start-up costs, $10,000 per provider in annual EHR maintenance costs, and over 8 hours in time to successfully meet Meaningful Use health IT and clinical quality reporting objectives. Yet, according to recently published articles, physician practices spend, on average, 2.6 hours per week and more than $15.4 billion dealing with the reporting of quality measures (Health Affairs; March 2016). Physicians are also spending more than 1 hour each day, uncompensated, handling these electronic communications, positioned at the computer instead of facing the patient. (JAMA Internal Medicine; March 2016).
- Smaller Practices Could Get Hit with Penalties: ACG urged CMS to delay implementing reimbursement cuts for practices with 25 eligible providers or less for the first 2 years (2019-2020), as well as APM threshold requirements related to certified health informational technology (IT) and Medicare patient volume/payments for the first 2 years (2019-2020). According to the data in the proposed rule, less than 50% of practices with 10-24 providers will receive a positive MIPS adjustment. These estimates are even more disturbing as the practice size gets smaller: roughly 30% of practices with 2-9 eligible providers and merely 3% of solo-practitioners will receive a positive adjustment in 2019.
More on MACRA: ACG Hopes to Keep This Simple. We compiled a detailed overview for you, hopefully in a simplified fashion and in plain English. Read the summary and potential impact to GI: Making $ense of MACRA
The 2016 ACG Annual Scientific Meeting and Postgraduate Course will also delve into the details of these changes, as well as offer strategies and insight on how to adequately prepare your practice for these upcoming changes.
From ACG Governor for Northern California, Neil H. Stollman, MD, FACG
Update on CA Bill Seeking to Waive Patient Cost-Sharing for Therapeutic and Diagnostic Screening Colonoscopy
On Wednesday, June 22nd, the California Senate Health Committee held a hearing for the recently introduced legislation, “Health Care Coverage: Colorectal Cancer Screening and Testing (AB 1763).” This bill, introduced by CA State Assemblyman Mike A. Gipson, has been endorsed by ACG as it shares the College’s goals of removing the financial and structural barriers associated with lifesaving colorectal cancer screenings throughout the screening continuum. ACG expressed our appreciation to State Senator and Chair of the Senate Health Committee, Ed Hernandez, for holding this hearing. We also highlighted those organizations located in his district that are committed to the public awareness campaign of getting 80% of eligible Americans screened by 2018. We will continue to keep our members up-to-date on the bill’s status, along with any similar legislation across other states.
Remember to contact your ACG Governor on important state and local issues impacting you and your practice.
The ACG Board of Governors is one of the most unique aspects of the American College of Gastroenterology. Governors are ACG Fellows that are elected from the membership of a particular state or region. There are currently 76 Governors across seven different regions in the U.S. and abroad. The Board of Governors acts as a two-way conduit between College leadership and the membership at-large. This helps the College make certain it is meeting the evolving needs of the membership.
This bill is also consistent with the SCREEN Act (S. 1079; HR 2035) at the federal level. ACG will continue to fight for lowering barriers to screening and reversing recent Medicare cuts to colonoscopy. Please click here to express your support for the SCREEN Act.