This Week – February 10, 2018

This Week in Washington, D.C.

  • ACG Advocacy Successful on Multiple Fronts: Congress Includes Various ACG Priorities in Two-Year Budget
  • FDA Safety Alert for ACG Members: Updated Status of Pentax Medical Duodenoscope Model ED-3490TK
  • GIQuIC and the MIPS 2018 QCDR Reporting Option
  • MACRA Tidbit for the Week: MACRA 2018: Back to the basics and key takeaways

From ACG President, Irving M. Pike, MD, FACG

ACG Advocacy Successful on Multiple Fronts: Congress Includes Various ACG Priorities in Two-Year Budget

Thank you ACG members for your advocacy. While there is much more to do, your efforts have paid off on multiple fronts.

This week Congress passed a two-year budget deal, along with a “continuing resolution” to keep the federal government open past February 9. This two-year budget agreement also includes various ACG public policy priorities that we advocated for over the past year. ACG appreciates all of your efforts! Please find below a summary of the various ACG priorities incorporated into this legislation.

MIPS Cost Performance Category

As part of this budget deal, Congress provides CMS the regulatory authority to lower/revise the MIPS Cost performance category an additional three years. This helps ease the transition into MIPS for another three years and helps reduce the threat of Medicare reimbursement cuts. ACG recently urged congressional leadership to include this language in any continuing resolution package. ACG Governors advocated for a change in the MIPS Cost performance category with policymakers back in April 2017. This was the first time many members of Congress and staff became aware of the problem.

Why is this important to ACG members?

When Congress passed MACRA in 2015, it provided CMS with flexibility to implement MIPS in only the first two years of the program. This may have major consequences, especially in the MIPS Cost performance category. This performance category is designed to measure and compare the costs of your physician services versus other providers performing the same services. Thankfully, this category had no impact on your final MIPS score in 2017 (weight of 0%). Yet, it will make up 10% of your final MIPS score in 2018. Absent a change, MACRA required CMS to increase this weighting to 30% of your total MIPS score beginning next year. Without these necessary legislative and regulatory changes, 30% of your total Medicare reimbursement will be based upon cost metrics which, according to CMS, have only “moderate” reliability. We need CMS to change the performance weights as we transition into MACRA, and CMS needed the regulatory authority to do this.

Repeals IPAB & more: read my full blog here.

FDA Safety Alert for ACG Members

Updated Status of Pentax Medical Duodenoscope
Model ED-3490TK

On February 7th, Pentax issued an “Urgent Medical Device Correction and Removal” notification informing customers of its voluntary recall of all ED-3490TK duodenoscopes. The recall was solicited in order to replace the forceps elevator mechanism, O-ring seal and distal end cap, and to update the Operation Manual to recommend annual maintenance.  According to the FDA, the design changes are intended to reduce the potential for leakage of patient fluids into the closed elevator channel and under the distal cap. The FDA cleared the updated design and labeling for the ED-3490TK on February 7th, 2018.  The reprocessing instructions for the recently cleared ED-3490TK have not changed since the February 2016 update.

GIQuIC and the MIPS 2018 QCDR Reporting Option

We are pleased to announce that the GIQuIC Registry has been approved as a Qualified Clinical Data Registry (QCDR) for reporting to the Merit-Based Incentive Payment System (MIPS) for the 2018 reporting year.

Since 2010, GIQuIC has grown in value as a clinical benchmarking tool for gastroenterology practices, with more than 6 million colonoscopy cases in January 2018 and growing. CMS approved GIQuIC as a QCDR for the 2014, 2015, 2016 and 2017 reporting years, facilitating endoscopists’ documentation of compliance with quality measures. The QCDR reporting mechanism is a dynamic reporting option that allows providers to report on MIPS and QCDR measures that are meaningful to their specialty practice and foster improvement in the quality of care provided to patients. More than 1,000 GIQuIC participants elected to utilize the GIQuIC QCDR for their reporting to CMS for the 2015, 2016 and 2017 performance years.

GIQuIC is hosting an informational webinar on Tuesday, February 27 at 2:00 pm Central Time to provide the details surrounding the QCDR reporting option and how the GIQuIC registry can help satisfy MIPS requirements for the 2018 reporting year. Join Dr. Brett Bernstein and GIQuIC staff for this presentation, which will include opportunities for Q&A. Register to attend the live webinar session or to receive updates on the availability of the recording of the session.

Click here to register for the webinar.

MACRA 2018: Back to the basics and key takeaways

MACRA Year 2: Acronyms and Background

On November 2, 2017, the Centers for Medicare and Medicaid Services (CMS) released “Quality Payment Program Year 2” final rule, outlining details of Medicare reimbursement policy changes for the 2018 reporting year. This rule outlines the details of the Merit-Based Incentive Payment System (MIPS), the modified Medicare Part B fee-for-service program for certain participating practitioners. This rule also establishes incentives for participation in certain alternative payment models (APMs) that allow providers to be excluded from participating in MIPS.

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 in 2017 (impacting the 2019 reimbursement year).

Key takeaway: In implementing MACRA, CMS calls this new program the “Quality Payment Program,” or “QPP.”

MACRA 2018: The 2 Year Lag (Reporting Year vs. Reimbursement Year)

What happens to your current reimbursement depends on what you did 2 years ago. Thus, your CY 2018 quality reporting impacts your CY 2020 payment year.   What you did in CY 2016 will shape your CY 2018 Medicare fee-for-service payments.  If you successfully participated in PQRS, “Meaningful Use,” etc. back in 2016, you may be eligible for a payment bonus in CY 2018.

In CY 2018, you will receive an annual fee schedule update of .41% absent anything you may have done during the CY 2016 reporting year.  Under MACRA, providers receive an annual MACRA update of .5% through December 2019.  However, CMS is also obligated to implement budgetary and other policy changes.  Thus, in 2018, the Medicare fee-for-service update equals .41% as opposed to .5%.

Key takeaway: Unlike the securities markets, past performance does help predict future results in Medicare Part B reimbursement.

2018 is another “Transition Year”

As you may recall, CMS eased the transition into MACRA in 2017.  If you made some sort of effort in quality reporting in CY 2017, you would avoid a payment cut in CY 2019.  More on 2017:  Making $ense of MACRA: 2017.  CMS also provided a side-by-side comparison that summarizes the final changes to the requirements for MIPS and APMs for calendar year 2018 compared to 2017.

CMS estimates that there are 11,298 MIPS-eligible GI clinicians in CY 2018. According to CMS estimates, 3% would receive a reimbursement cut in CY 2020, while 97% would be eligible for a bonus or would at least avoid a payment cut.  The estimates for smaller practices are not as positive: CMS approximates that there are 116,626 MIPS-eligible clinicians in practice sizes 1 to 15. Of these practices, 9% are expected to receive a payment cut.

Key take away: The maximum payment cut for the 2020 payment year is 5% for those who do not report MIPS measures in CY 2018. This is a deeper cut from the 4% payment adjustment for not participating in MIPS in 2017 (which impacts payment in CY 2019).

Stay tuned for more next week.