This Week – January 13, 2018
This Week in Washington, D.C.
- CMS Announces New Medicare Episode Payment Bundle- Here’s what you need to know
- Updated MACRA Information for 2018: ACG’s Guidance Tailored for GI Clinicians
- At the State and Local Level: MOC-related bill introduced in Virginia
- MACRA Tidbit for the Week: MedPAC Votes to Get Rid of MIPS
From ACG Legislative and Public Policy Council Chair, Whitfield L. Knapple, MD, FACG
CMS Announces New Medicare Episode Payment Bundle- Here’s what you need to know
This week, the Centers for Medicare & Medicaid Services (CMS) announced a new voluntary episode payment model, the “Bundled Payments for Care Improvement Advanced” (BPCI Advanced). This will test a new iteration of bundled payments for 32 Clinical Episodes (see below for GI episodes). BPCI Advanced will qualify as an Advanced Alternative Payment Model (APM) under MACRA, or the Quality Payment Program. This means that ACG members in group practices can select to be held accountable for certain inpatient episodes of care instead of participating in MIPS (there are no outpatient-related GI episodes of care at this time).
ACG members meeting certain reporting thresholds must either participate in MIPS, or in a CMS-approved Advanced APM.
A bundled payment model involves combining the payments for physician, hospital, and other health care provider services into a single bundled payment amount. This amount is calculated based on the expected costs of all items and services furnished to a patient during an episode of care. The goal being to motivate health care providers to furnish services efficiently, to better coordinate care, and to improve the quality of care (and save the system money). Health care providers receiving a bundled payment may either realize a gain or loss, based on how they manage resources and total costs throughout each episode of care. According to CMS, a bundled payment also creates an incentive for providers and suppliers to coordinate and deliver care more efficiently, because a single bundled payment will often cover services furnished by various health care providers in multiple care delivery settings.
BCPI Advanced Model Overview
The newly announced BPCI Advanced model is defined by following characteristics:
- Participation is voluntary
- Based on a single retrospective bundled payment and one risk track, with a 90-day Clinical Episode duration
- Qualifies as an Advanced APM under MACRA (or the Quality Payment Program)
- Payment is tied to performance on quality measures
- Preliminary “Target Prices” are provided in advance of each Model Year
BPCI Advanced will operate under a “total-cost-of-care” concept, where the total Medicare fee-for-services (FFS) spending on all items and services furnished during the clinical episode will be included as expenditures and compared to a “Target Price” (exclusions do apply).
Participating hospitals and physician group practices (PGPs) must commit to be held accountable for one or more clinical episodes beginning in October 2018, and may not add or drop such Clinical Episodes until January 1, 2020.
For purposes of BPCI Advanced, a “Participant” is defined as an entity that enters into a Participation Agreement with CMS to participate in the Model. BPCI Advanced will require a downside financial risk of all Participants from the outset of the Model Performance Period.
From ACG Practice Management Committee Chair, Louis J. Wilson, MD, FACG
Updated MACRA Information for 2018: ACG’s Guidance Tailored for GI Clinicians
ACG members are encouraged to check out ACG’s updated “Making $ense of MACRA” guidance. Like last year, ACG hopes to keep it simple, keep you well informed, and keep it tailored to clinical GI. These guidance materials walk you through the 2018 reporting requirements, the various acronyms, the changes to MIPS, as well as the revised requirements for APM reimbursement models. ACG also provides practical examples of how CMS calculates your MIPS’ score, all structured and formatted for busy GI practices and clinicians.
At the State and Local Level:
MOC-related bill introduced in Virginia
Some good news at the state and local level: Virginia Representative Sam Rasoul (D-VA-011) has recently introduced HB 157, legislation which would prohibit Maintenance of Certification (MOC) from being required as a condition for hospital admitting privelages, insurer reimbursement, or state licensure. We need your support to use our legislative voices to call for a rational approach to MOC to your local representatives. ACG supports the principles of lifelong learning for physicians, as evidenced by ongoing continuing medical education (CME) activities, rather than an onerous process of lifelong testing with redundant requirements levied by an independent third party. Help ACG raise awareness of state legislative options in Virginia prohibiting high stakes exams and costly maintenance of board certification requirements.
To help make an impact, your state legislators need to hear from you directly, and the ACG website makes this process quick and simple. Use the links below to advocate your support. Be sure to contact your ACG Governor to bring light to any additional local issues that are important to you.
MedPAC Votes to Get Rid of MIPS
This week, the Medicare Payment Advisory Committee (MedPAC) voted 14-2 to recommend that Congress already repeal MACRA’s Merit-based Incentive Payment System (MIPS) and replace with yet another reimbursement system. What does this mean? Well, nothing at this point. MedPAC is an influential Medicare payment advisory board created by Congress, but Congress can choose to ignore any MedPAC recommendations (and they often do). It is unlikely that Congress has any interest in major revisions to MIPS. However, MedPAC is still very influential so this is worth taking notice and monitoring.
During this recent MedPAC meeting, staff stated plainly their view that MIPS “cannot succeed.” The program, they said, replicates the flaws of prior reimbursement programs and is burdensome to clinicians. Additionally, scores are not comparable across physicians. MIPS payment adjustments will be minimal in the first two years, followed by large and arbitrary adjustments in later years. Staff expressed that on the whole, MIPS will not succeed in helping beneficiaries choose clinicians, helping clinicians change practice patterns, or helping Medicare to reward clinicians based on value.
As an alternative approach, MedPAC has proposed a voluntary value program (VVP). In brief, it would maintain the value component in traditional fee-for-service Medicare, but with a stick approach of encouraging clinicians into alternative payment models (APM). An upfront “withhold” would be applied to all fee schedule payments. Clinicians could either elect to join a voluntary group and have their performance assessed at the group level, or join an APM, and receive their “withhold” back. If a clinician makes no election at all, the clinician then forfeits the opportunity to get this “withhold” back.