This Week – November 4, 2017

This Week in Washington, D.C.

  • CMS Releases Final CY 2018 MIPS & APMs Requirements
  • Medicare Seeks Your Feedback on MIPS Colonoscopy Episode
  • Legislative action alert: urge your representatives to support S.2051/HR.4206!
  • Tri-Society Alert: 2018 Medicare Payment Rules Released
  • Questions on Biosimilars in IBD?  Slides from the recent ACG Workshop with the FDA and EMA

From ACG Legislative and Public Policy Council Chair, Whitfield L. Knapple, MD, FACG

CMS Releases Final CY 2018 MIPS & APMs Requirements

On Thursday, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2018 Medicare Quality Payment Program (QPP) final regulation. This regulation outlines the requirements for year 2 of the Merit-based Incentive Payment System (MIPS), as well as for qualified or “Advanced” Alternative Payment Models (APMs) under MACRA.

ACG is currently reviewing the final rule’s impact upon clinical GI, and will share more details in later communications. For immediate consideration, here is a brief overview and top-line summary.

Read the CMS Summary of QPP Year 2 Final Rule Here.


CMS 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. According to CMS estimates, 3% would receive a reimbursement cut in CY 2020, while 97% would be eligible for a bonus, or at least avoid a payment cut.

The estimates for small 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.

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 the payment for CY 2019.

ACG Advocacy Paying Off – Exemptions for
Hard Hit Hurricane Areas

In Thursday’s final rule, CMS announced establishing an automatic “extreme and uncontrollable circumstance” policy for the 2017 MIPS performance period that recognizes recent hurricanes (Harvey, Irma, and Maria) and other natural disasters can effectively impede a MIPS eligible clinician’s ability to participate in MIPS. ACG has advocated CMS to do this so we are very encouraged that CMS listened to the College in announcing this policy change.

What does this change in 2018 Final Rule mean for 2017 Reporting Year?

  1. Clinicians in affected areas who do not submit data will not receive a payment cut in CY 2019.
  2. Clinicians who do submit data will be scored on their submitted data.
  3. The policy applies to individuals (not group submissions), but all individuals in the affected area will be protected for the 2017 MIPS performance period.
  4. This policy does not apply to APMs.

MACRA Final Rule Top-Line Summary: click here to read the full post.

From ACG Legislative and Public Policy Council Member and ACG Board of Trustee, Caroll D. Koscheski, MD, FACG

Medicare Seeks Your Feedback on MIPS Colonoscopy Episode

As ACG and the GI societies notified you earlier this month, CMS recently announced that it will begin a trial run or test period for a “Screening/Surveillance Colonoscopy” episode of care. We need your feedback and input!

What does this mean?

From October 16 to November 20, 2017, ACG members may receive a confidential report with information about their performance on this draft episode of care. According to CMS, the report is available for group practices and solo practitioners who meet a 10-episode case minimum during the measurement period of 06/01/16 to 05/31/17.

The purpose of this report is to help improve the accuracy and understanding of the process, and for our members to provide feedback to CMS.

Your Feedback is Important- Complete the Survey

CMS will be seeking feedback from all stakeholders through an online survey. Please complete this survey here.

This survey opened on October 16, 2017 and closes at noon Eastern time on November 20, 2017. The field test reports for group practices and solo practitioners will be distributed through the CMS Enterprise Portal, which CMS has previously utilized for “Quality and Resource Use” Reports. If you do not already have an account, you can set one up and get access to a “Physician Quality and Value Programs” role in preparation for the field test report by using this guide.

Some background- Why do we need to do this? Click here to read the full blog.

Legislative Action Alert:
Urge your representatives to support S.2051/HR.4206!

This week, a bill was introduced in both the U.S. House and Senate which aims modernize Stark Law and physician self-referral limitations for those GI practices wishing to explore alternative payment models.  The “Medicare Care Coordination Improvement Act of 2017″ (S. 2051/HR.4206), introduced by Senators Portman (R-OH) and Bennet (D-CO), and Representatives Bucshon (R-IN), Ruiz, MD (D-CA), Marchant (R-TX) and Kind (D-WI), allows CMS to create exemptions for medical practices who are in the process of joining an alternative payment model (APM).  CMS continues to explore better approaches and incentives for specialists to join an APM.  More must be done, however, as current APMs may not be the right fit for smaller, non-integrated GI practices.  Thus, ACG, along with several other medical associations across the healthcare spectrum, are in support of S. 2051/HR.4206, as the legislation may allow more creativity and opportunity for independent GI practices to explore APMs without the fear of Stark Law violations.

We need your help: please reach out to your elected officials and urge them to support these important health policy issues impacting ACG members and your patients.  Our website makes this process quick and simple.

Take action now!

Tri-Society Alert:
2018 Medicare Payment Rules Released

CMS has released two calendar year (CY) 2018 rules that finalize policy and payment changes for the Medicare Physician Fee Schedule (PFS) and the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System.

ACG, AGA and ASGE are collaborating to review the details of the 2018 final rules. A brief overview is listed below. Click here for a more detailed overview of changes impacting GIs.

Medicare 2018 Physician Fee Schedule

2018 Medicare Physician Fee Schedule Final Rule

  • The 2018 PFS Conversion Factor is $35.99.
  • CMS valued new codes for anesthesia for GI procedures. The AMA CPT Editorial Panel will delete CPT codes 00740 (Anesthesia for upper GI procedures) and 00810 (Anesthesia for lower GI procedures) in CPT 2018 and replace them with five new codes. While codes 00740 and 00810 currently have 5 base units, the new 2018 codes will have between 3 and 6 base units. Each base unit is approximately $22.
  • CMS did not update malpractice (MP) RVUs, preventing further cuts to GI reimbursement. CMS did not finalize its proposal to update CY 2018 MP RVUs using premium data collected for the CY 2018 update of the MP geographic practice cost indices (GPCIs). CMS’ decision not to finalize this policy acknowledges a need to resolve variances in the available data and to review methods used to apply these data in the calculation of MP RVUs.

2018 OPPS/ASC Payment System: click here to read the full alert.

From ACG FDA-Related Matters Committee Chair, Tedd P. Cain, MD, FACG

Questions on Biosimilars in IBD?  Slides from the recent ACG Workshop with the FDA and EMA

On October 23, The U.S. Food and Drug Administration (FDA) released a public bulletin on biosimilar drugs.  The FDA has recently has approved biosimilar products to treat conditions such as cancer, Crohn’s disease and colitis, irritable bowel syndrome, and more.  But what are biosimilars?  The FDA continues to roll-out educational materials for providers.

What are the practical implications for GI clinicians prescribing IBD medications? 

ACG’s FDA Related Matters Committee hosted a public workshop with the FDA and the European Medicines Agency (EMA) and addressed this question at last month’s WCOG at ACG 2017.  The workshop compared the approval processes of biosimilar drugs in both agencies, with a focus on IBD.  The EMA provided some insight from their history of approving biosimilar drugs in IBD.  The FDA also provided some practical tips for ACG members and GI clinicians.  Did you miss this workshop?  In need of some practical guidance?

Click here to view the slides on the ACG website.