This Week – March 17, 2018

This Week in Washington, D.C.

  • Call to Action: Urge your representatives to support the “Removing Barriers to Colorectal Cancer Screening Act” (S. 479; HR 1017)!
  • ACG Co-hosting Meeting with FDA: GREAT 5 for Pediatric Irritable Bowel Syndrome and Pediatric Functional Constipation
  • Good news for ACG members: Anthem rescinds modifier 25 payment policy
  • MACRA Tidbit for the Week: Crash course on MIPS Bonuses and Cuts

Call to Action:
Urge your representatives to support the “Removing Barriers to Colorectal Cancer Screening Act” (S. 479; HR 1017)!

In honor of Colorectal Cancer Awareness month, take action now and urge your legislators to support the “Removing Barriers to Colorectal Cancer Screening Act!” This legislation fixes a Medicare coverage quirk by waiving Medicare beneficiary cost-sharing when screening colonoscopies turn therapeutic. Right now, Medicare only has the authority to waive the patient coinsurance for colonoscopies that remain a “screening.”

Colorectal cancer is the second leading cause of cancer deaths in the United States, with over 50,000 Americans expected to die from colorectal cancer this year alone. While this country is making progress against colorectal cancer incidence rates and mortality, more needs to be done to increase the use of screening tests by Medicare beneficiaries.

To help make an impact, your legislators need to hear from you directly, and the ACG website makes this process quick and simple. Use the link below to advocate your support.

Click here to take action now!


ACG Co-hosting Meeting with FDA

GREAT 5 for Pediatric Irritable Bowel Syndrome and Pediatric Functional Constipation

The ACG, American Gastroenterological Association (AGA), North American Society for Pediatric Gastroenterology, Hepatology, and Nutrition (NASPGHAN) and FDA will be cosponsoring a public workshop in Silver Spring, Maryland on March 28, 2018, titled the Gastroenterology Regulatory Endpoints and the Advancement of Therapeutics, or GREAT 5.

The focus of this public workshop is Pediatric Irritable Bowel Syndrome and Pediatric Functional Constipation. The co-sponsored workshop will facilitate the ongoing dialogue among relevant parties on issues related to these pressing topics.

On-site registration will not be available.

Register here.

Click here for more information.


Call to Action:
Urge your representatives to support the “Restoring the Patient’s Voice Act of 2017” (HR 2077)!

Please contact Congress on a very important patient advocacy and practice management issue.  ACG has focused efforts to limit insurer “Step Therapy” requirements at both the federal and state level.  Step Therapy entails the “fail first” drug therapy requirements, in which patients are forced by insurers to try and fail with one or more medications before the insurer approves the cost of the medication which ACG members originally prescribed.  Representative Brad Wenstrup (R-OH) has introduced the “Restoring the Patient’s Voice Act of 2017” (HR 2077), which allows for exemptions for Step Therapy requirements in health plans regulated by federal law.

ACG Governors and members continue to express the frustration over the amount of time and resources GI practices spend dealing with insurers and prior authorizations, at the detriment to patient care. These policies are not rooted in clinical evidence, and ultimately take valuable time away from treating patients.  ACG continues to stress the importance of protecting the sanctity of the patient-physician relationship.

To help make an impact, your legislators need to hear from you directly, and the ACG website makes this process quick and simple.  Use the link below to advocate your support.

Click here to take action now!


2018 MIPS scoring in a nutshell

MIPS Scoring- Target for 2018 is at least 15 points to avoid a cut in 2020

In CY 2018, CMS increased the MIPS threshold to 15 points.  This means that you must score at least 15 points in total to avoid a payment cut in CY 2020.  The size of your cut will depend on the amount of data you submit for CY 2018, up to a maximum cut of 5% of Medicare Part B allowable charges.

The BAD: The Cuts… sliding scale from less than 15 points to 0, with maximum of 5% of your Medicare Part B fee for service allowable charges.  The maximum cuts from failing to participate in MIPS are defined in MACRA (2020: -5% based on CY 2018 reporting year).

The GOOD: The Bonuses… “Scaling Factor up to 3x the maximum cut to determine the positive adjustment.”  This is also defined in MACRA (2020: +5 – 15% based on CY 2018 reporting year).

What does this “scaling factor up to 3x the maximum cut to determine the positive adjustment” actually mean? A provider could be eligible for up to a 15% bonus in 2020, but this depends on the actual maximum reimbursement cut to other providers in that particular year.  Ultimately, your bonus depends upon the lack of performance of others. It does not mean the successful MIPS scoring providers are assured a 5-15% bonus.

KEY TAKEAWAY: THERE MUST FIRST BE CUTS IN ORDER FOR THE POOL OF BONUS MONEY

  • This suggests that as the cuts get higher, and the requirements become fully implemented, funds will become available to provide the MIPS bonuses.  This also suggests that as CMS “transitions” clinicians into MIPS and helps clinicians with avoiding reimbursement penalties, this in turn limits the funds available for MIPS bonuses.

Exception to the Key Takeaway: The MIPS “Exceptional Performance Bonus”

MACRA provides that the 25th percentile of all aggregate MIPS scores can receive additional bonuses that are NOT subject to budget neutrality rules discussed above (2019 – 2025).  For 2018, the target threshold MIPS score to meet in order to receive the “exceptional performance bonus” is 70.

  • The bonus is an annual $500 million distributed among providers in this category (2019-2025).
  • The bonus is capped at a 10% bonus per eligible provider.

Here’s the MIPS sliding scale for 2018:

2020 Payment Year (2018 reporting year)
Final MIPS Score Payment Adjustment
0-3.75 You receive the maximum 5% payment cut.
3.76-14.99 You receive a payment cut that is less than 5%, depending on how your score falls in a linear sliding scale.
15 You receive no payment cut and are not eligible for a payment bonus.
15.01-69.99 You are eligible for a payment bonus, depending on how your score falls in a linear upwards scale, and if there are providers receiving a payment cut in order to pay for your and others’ payment bonus.
70-100 You are eligible for a payment bonus, depending on how your score falls in a linear upwards scale and if there are providers receiving a payment cut in order to pay for your and others’ payment bonus.

AND

You are eligible for the “exceptional performance” payment bonus.  This is not subject to budget neutrality rules. The amount of the $500 million depends on how many providers are scoring 70+ points (capped at 10% for each provider).

Note: Bonuses points for complex patients

ACG has been very active advocating for GI practices, as well as greater risk adjustments for complicated patients, during this transition into MIPS.  We are glad to see that CMS is listening. All providers and groups can also earn a 5% bonus to their MIPS score in 2018 for treating complex patients.  “Complexity” is based on medical complexity, as measured by the Hierarchical Condition Category (HCC) risk score, and a score based on the percentage of dual-eligible (Medicare and Medicaid) beneficiaries.  Clinicians or groups must submit data on at least 1 performance category in an applicable performance period to earn the bonus.