This Week in Washington DC – March 24, 2018

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.

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.

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.

The MIPS Quality Performance Category in 2018: The basics, and some helpful scoring examples

The Quality Category represents 50% of your MIPS score for the CY 2018 reporting year. This performance category is similar to the old physician quality reporting system (PQRS), where you choose from a list of CMS-approved quality measures and can select the way in which you submit your data. You select 6 measures from a list of 270+ total measures. If fewer than 6 measures apply, the GI clinician would be required to report on each measure that is applicable. The reporting period is the entire CY 2018.

CMS also provided a suggested list of common quality measures reported by GI providers. This is known as the “gastroenterology specialty measure set.” It is not required that ACG members select measures from this list.

Where do I go to select a measure and find measure requirements?

Visit ACG’s Making $ense of MACRA website, or Medicare Quality Payment Program resource library to find the list of measures for 2018, as well as the reporting requirements and measure specifications for each measure.

Quality Category: Scoring

Please Remember: Each MIPS performance category has its own scoring system. Scores from each performance category will be converted into an aggregate MIPS score (scale of 0-100).

For CY 2018, CMS states that the maximum quality performance score will continue to be 60 points for solo practitioners and groups of 15 or fewer clinicians (6 submitted measures x 10 points =60) and 70 points for groups of 16 or more, as CMS will calculate a “population measure” for these groups (6 submitted measures x 10 points + population measure x 10 points). The methodology:

• 10 points for each of the 6 measures reported, and 10 points for 1 population measure for groups of 16 or more.
• Clinicians and groups reporting a measure set of more than 6 measures would be credited for their performance on their best 6 measures.
• Clinicians and groups who do not satisfy the 60% data completeness standard for a quality measure would receive 1 point. However, CMS will continue to award small practices 3 points for measure that don’t meet data completeness requirements.
• Clinicians and groups who satisfy the 60% data completeness standard for a quality measure receive 3 points at minimum. (Thus, you would earn above the 15 MIPS total points threshold and avoid a payment cut).
• 2 bonus points for each outcome and patient experience measure reported.
• 1 bonus point for other high priority measure reported in addition to the one high priority measure required (10 possible points).
• Bonus also provided for use of certified electronic health record technology or “CEHRT” (up to 10 possible bonus points)

Quality: Performance Requirements – Population-Based Measures

MACRA provides that the Secretary may use global measures, such as global outcome measures, and population-based measures for purposes of the quality performance category—CMS is choosing to use this authority for group practices of 16 or more. This will be included in the providers’ overall Quality score. Practices do not actually report data. Instead, CMS will calculate an “all cause hospital readmissions” population-based measure based on Medicare claims data. (Minimum of 200 cases)

Quality Category: Improvement Score

For 2018, CMS will begin to include an “improvement component” to the Quality performance category. Quality improvement scoring is calculated at the category level (not for each measure) for up to 10 points toward the total score. CMS will calculate this by comparing your quality score to your quality scores in previous years. The methodology is captured by the following equation:

Quality Improvement Score = (Absolute Improvement/Previous Year Quality Performance Category Percent Score Prior to Bonus Points) / 10

Real World Example 1: The Solo Practitioner

If a MIPS-eligible solo practitioner submitted 5 quality measures, and scored 9 out of 10 on each measure, but reported another measure that was below the required data completeness standard, the clinician would receive 40 points for the Quality performance category, which would then be weighted to 50% of the total MIPS score.

(5 measures X 9 points) + (1 measure X 3 point small practice threshold) or 48 out of 60 possible points, 48/60 X 50 (weight of quality performance category) = 40 points toward the total MIPS score.

This performance alone already exceeds the 15 point floor for the transition year, which would avoid a payment reduction in 2020. The solo practitioner would also be eligible for a “small practice” bonus for the final MIPS score.

Real World Example 2: The Group Practice of 20

If a group of 20 MIPS-eligible physicians reported on only 2 measures, but failed to meet the data completeness standard of 60% for one, the group would receive the minimum floor of 1 point for one measure and up to 10 points for the second. Additionally, the group will be automatically scored on the population-based measure. Assume the group was awarded 10 points for high performance. The group would receive 15 points for the Quality performance category, which would then be weighted to 50% of the total MIPS score.

(1 measures X 1 point) + (1 measure x 10 points) + (1 population measure X 10 points) or 21 out of 70 possible points, 21/70 x 50 (weight of quality performance category) = 15 points toward the total MIPS score.