This Week – September 17, 2016

This Week in Washington, D.C.

  • ACG President Ken DeVault Conveys Frustration to ABIM
  • MACRA Tidbit for the Week: CMS Eases MACRA requirements for CY 2017
  • GI Societies Meet with CMS on Sedation

ACG President Ken DeVault Conveys Frustration to ABIM

This week, ACG President Ken DeVault, MD, FACG, participated in a meeting convened by the American College of Physicians, including representatives from the American Board of Internal Medicine (ABIM).  Read Dr. DeVault’s recent update on the meeting in the ACG President’s Blog: Sending a Signal on MOC.

From Dr. DeVault’s blogpost: “I traveled to Philadelphia today because I feel strongly that my presence sends a signal conveying the importance of this issue for ACG members.  To me, it’s imperative that the ABIM leadership recognize the level of dissatisfaction over MOC among ACG members.”

Keep track of ACG’s efforts to make the MOC process less complicated, more clinically relevant, and less expensive for those who wish to maintain board certification.   “We support the principles of lifelong learning as evidenced by ongoing CME activities, rather than lifelong testing.”

The ACG Board of Governors is committed to change at the state level as well, advocating on your behalf through efforts including updating members on recent changes in legislation involving MOC in North Carolina and Oklahoma.  Fortunately, the unique function and structure of the ACG Board of Governors is a natural fit for these issues, allowing the College to be actively engaged at the state level.  Contact your ACG Governor to help get your state involved.


CMS Eases MACRA requirements for CY 2017

The Centers for Medicare and Medicaid Services (CMS) announced last week that the Agency will ease reporting restrictions and potential payment cuts under Medicare’s new reimbursement law.  As you know, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repealed the Medicare sustainable growth rate (SGR) formula and created a new reimbursement system beginning 2019.  However, CMS will use CY 2017 as the reporting year to determine your 2019 payment.

While CMS did announce some help in this transition, the Agency also stated that it would release the final rule by November 1, 2016.  CMS announced the following reporting options for CY 2017 to avoid reimbursement cuts in CY 2019:

First Option: The Test Option

CMS stated that as long as ACG members “submit some data” for MIPS after January 1, 2017, they will avoid a payment cut in 2019.  According to CMS, “this first option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more.”

Second Option: Partial Year Participation

CMS stated that ACG members may choose to submit MIPS information for a portion of CY 2017 and could still qualify for a “small positive” payment bonus in 2019.

Third Option: Full Speed Ahead

For ACG members that are ready to go on January 1, 2017, your “first performance period” would begin on January 1, 2017, and you could qualify for a “modest bonus” in 2019, according to CMS’ announcement.**

** Wait, a “modest bonus” for reporting for the full CY 2017? What happened to all of this talk about getting a bonus of up to 12% in 2019 if you successfully participant in MIPS in CY 2017?  Great question.  Remember, ACG has informed members to be careful, as this MIPS program requires “budget neutrality,” or other providers to fail first in order for you to get a bonus…..  So it is very difficult to receive a bonus up to 12% in 2019 if very few providers are subject to any reimbursement cuts in 2019.  The irony is that this CMS announcement may actually incentivize providers to not participate for the full CY 2017, even if their practices are ready to go on January 1, 2017.   Should MIPS be called the OGMFF or the “other guy must fail first” payment system?

Please note, however, this full year option may help ACG members achieve the “exceptional performance bonus” category of MIPS, which is not subject to budget neutrality rules.  Providers in the top 25% of all aggregate MIPS scores from 2019 to 2025 receive an additional positive adjustment factor, or an “Exceptional Performance Bonus.”  This bonus is not subject to budget neutrality rules.  There will be $500 million distributed evenly each year for 6 years for these payments, bonuses capped at 10% per eligible provider.  In the proposed rule, CMS estimates that $13 million of this $500 million would be eligible for GI.

Fourth Option: Participate in an Advanced Alternative Payment Model

CMS also announced that joining an Advanced Alternative Payment Model, “such as Medicare Shared Savings Track 2 or 3 in 2017” is another option for ACG members.  If ACG members receive enough Medicare payments or see the required Medicare patients through the Advanced Alternative Payment Model in 2017, then members would qualify for a 5% bonus in 2019.  However, be careful –  this yearly 5% bonus stops in 2025.

Why the Change?

This announcement comes on the heels of a bipartisan congressional letter to CMS, urging CMS to implement greater flexibility in MACRA reporting requirements.  ACG welcomes this news, but continues to urge CMS to delay and revise MACRA requirements even further.  As noted by CMS in the announcement, the final rule will be released by “November 1, 2016.”

This affords ACG members and GI practices roughly two months to understand the details, and then be able to compare and consider these reporting options outlined by CMS this week.  Thus, ACG continues to advocate for more time to transition into MACRA, especially for smaller and independent GI practices.  MACRA is here to stay for the time being, but ACG is committed to improving this law and reducing your practice management and financial headaches caused by this law.

GI Societies Meet with CMS on Sedation

On September 6, ACG, AGA, and ASGE responded to major provisions in the 2017 Medicare Physician Fee Schedule (MPFS) Proposed Rule Payment Policy, as well as major provisions in the CY 2017 Hospital Outpatient Prospective Payment System (HOPPS)/Ambulatory Surgery Center (ASC) Proposed Rule.

ACG, AGA, and the ASGE recently met with CMS officials to reinforce our recommendations on important payment issues impacting GI in the proposed rules.  R. Bruce Cameron, MD FACG represented the ACG.   During our meeting, we urged CMS to (please click here to read the rest of the blog).