Check your MIPS Eligibility Status for 2018: do you have to participate in MIPS?
From ACG Legislative and Public Policy Council Chair, Whitfield L. Knapple, MD, FACG
Check your MIPS Eligibility Status for 2018: Do you have to participate in MIPS?
The Centers for Medicare and Medicaid Services (CMS) recently announced that ACG members can now check their 2018 eligibility for Medicare’s Merit-based Incentive Payment System (MIPS). Keep in mind that being “ineligible” for MIPS is not necessarily a bad thing, as CMS exempts from MACRA certain ACG members with low Medicare patient volume. If deemed ineligible, you would avoid any payment cuts in CY 2020 for not participating in MIPS in 2018, but you will also be ineligible for a potential bonus.
Trump Administration Releases Report on Lowering Drug Costs
On Friday afternoon, President Trump released an anticipated report on lowering drug costs in the U.S. You can access the report, entitled “American Patients First” by clicking here.
While the report does not provide much in detail, it outlines key objectives and initiatives on how to achieve these goals:
Increased Competition: Steps to prevent manufacturer gaming of regulatory processes, such as Risk Evaluation and Management Strategies (REMS); Measures to promote innovation and competition for biologics; Developing proposals to stop Medicaid and Affordable Care Act programs from raising prices in the private market; Considering how to encourage sharing of samples needed for generic drug development; Additional efforts to promote the use of biosimilars.
Better Negotiation: Experimenting with value-based purchasing in federal programs; Allowing more substitution in Medicare Part D to address price increases for single- source generics; Reforming Medicare Part D to give plan sponsors significantly more power when negotiating with manufacturers; Sending a report to the President on whether lower prices on some Medicare Part B drugs could be negotiated for by Part D plans; Leveraging the Competitive Acquisition Program in Part B; Working across the Administration to assess the problem of foreign free-riding.
Further Opportunities: Considering further use of value-based purchasing in federal programs, including indication-based pricing and long-term financing; Removing government impediments to value-based purchasing by private payers; Requiring site neutrality in payment; Evaluating the accuracy and usefulness of current national drug spending data; Investigating tools to address foreign government threats of compulsory licensing or IP theft that may be harming innovation and development, driving up U.S. drug prices.
Incentives for Lower List Prices: FDA evaluation of requiring manufacturers to include list prices in advertising; Updating Medicare’s drug-pricing; dashboard to make price increases and generic competition more transparent; Measures to restrict the use of rebates, including revisiting the safe harbor under the Anti-Kickback statute for drug rebates; Additional reforms to the rebating system; Using incentives to discourage manufacturer price increases for drugs used in Part B and Part D; Considering fiduciary status for Pharmacy Benefit Managers (PBMs); Reforms to the Medicaid Drug Rebate Program; Reforms to the 340B Drug Discount Program; Considering changes to HHS regulations regarding drug copay discount cards.
Lowering Out-of-Pocket Costs: Prohibiting Part D contracts from preventing pharmacists’ telling patients when they could pay less out-of-pocket by not using insurance; Improving the usefulness of the Part D Explanation of Benefits statement by including information about drug price increases and lower cost alternatives; More measures to inform Medicare Part B and D beneficiaries about lower cost alternatives; Providing better annual, or more frequent, information on costs to Part D beneficiaries.
ACG is reviewing the report and will continue to update membership on its impact to clinical GI. ACG will also continue to work with the Trump Administration and Congress in efforts to lower the costs of, and bring greater access to, medications for your patients.
At the state and local level: ACG members in Minnesota: “Step Therapy override” bill passes the House; urge your representatives to support the Senate bill!
This week, the Minnesota House unanimously passed the House “Step Therapy Override” bill (HF.3196), introduced by State Representative Kelly Fenton. The next step now awaits with its Senate counterpart, introduced by State Senator Paul Utke (SF.2897). These bills set certain requirements for insurers when establishing step therapy protocols, and require insurers to allow for a convenient and transparent process to override any step therapy protocols under certain scenarios.
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. ACG has focused efforts to limit insurer “Step Therapy” requirements at both the federal and state level. Representative Brad Wenstrup (R-OH) has introduced the federal “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. Last month, over 50 ACG Governors and members of the ACG Leadership advocated for this bill on your behalf during the 2018 ACG Board of Governors Legislative Fly-In.
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 links below to advocate your support.
GIQuIC 2018 QCDR: MIPS Dashboard Demonstration
The GIQuIC Registry is a CMS-approved Qualified Clinical Data Registry (QCDR) for reporting to the Merit-Based Incentive Payment System (MIPS) for the 2018 reporting year. On Wednesday, June 13 at 2:00 pm Central Time, GIQuIC will present a demonstration of its 2018 MIPS Dashboard, which registry participants would utilize if they choose to use the GIQuIC QCDR as their mechanism for public reporting.
GIQuIC hosted an informational webinar on February 27 to provide the details surrounding the QCDR reporting option and how the GIQuIC registry can help satisfy MIPS requirements for the 2018 reporting year. To access the slide deck and recording of the presentation, visit www.giquic.gi.org and click on the Quality Reporting Programs page. To discuss registering with GIQuIC to report via the 2018 GIQuIC QCDR, please contact firstname.lastname@example.org.
MACRA Tidbit for the Week: The MIPS “Improvement Activities” Performance Category
The MIPS “Improvement Activities” Performance Category
What do you need to know for 2018?
This category was established in MACRA. MACRA defines a “clinical improvement activity” as: an activity that eligible clinician organizations and other relevant stakeholders identify as improving clinical practice or care delivery. The Secretary determines, when effectively executed, that this activity will likely result in improved outcomes.
This category is 15% of the total composite MIPS score in 2020+.
What are “Improvement Activities?”
CMS has a list of 112 differently weighted “improvement activities.” ACG members attest to incorporating these activities into daily practice over 90 continuous days during the 2018 reporting year. Each activity is individually weighted to determine a score within this category. You review and select the activities that best fit your practice. Some examples:
- You can earn credit for ACG CME courses: “Medical Education (CME) programs as eligible to receive improvement activity credit and allow other improvement activities in the inventory to count towards CME” (medium weight).
- You can earn credit for participating in qualified clinical data registry, such as GIQuIC.
Important: A simple attestation or “yes” is all that is required to completing an Improvement Activity. Record documentation is key.
Important for ACG members reporting as a group practice: only one clinician in each TIN must attest to performing an Improvement Activity for the TIN to get credit.
What is the Improvement Activities scoring system?
CMS loves complexity. Each MIPS performance category has its own scoring system. For this performance category, you earn a maximum of 40 points to receive the highest score for the improvement activities performance category. Some examples:
- Reporting of one medium-weighted activity would result in 10 points.
- Reporting of two medium-weighted activities would result in 20 points.
- Reporting of three medium-weighted activities would result in 30 points.
- Reporting of four medium-weighted activities would result in 40 points.
- Reporting of one high-weighted activity would result in 20 points.
- Reporting of two high-weighted activities would result in 40 points.
- Reporting of a combination of medium-weighted and high-weighted activities where the total number of points achieved are calculated based on the number of activities selected and the weighting assigned to that activity (number of medium-weighted activities selected x 10 points + number of high-weighted activities selected x 20 points).
Attention Small Practices: CMS has finalized a different weighted system for small practices (groups of 15 and under), as well as those in rural areas:
- Reporting of one medium-weighted activity would result in 20 points.
- Reporting of two medium-weighted activities would result in 40 points.
- Reporting of one high-weighted activity would result in 40 points.
- Reporting of one medium-weighted activity would result in 20 points.
How do I report these activities to receive credit?
You can log in and attest to these activities on CMS’ Quality Payment Program website.
Please check out GIQuIC to learn how to complete this via a CMS-certified QCDR.
Improvement Activities performance category: Scoring Examples
A solo practitioner attests to 2 “medium” weight Improvement Activities. This performance already meets the 15 point “performance threshold” for 2018 to avoid a payment reduction in 2020.
(2 medium-weighted activities x 20 points) or 40 out of 40 possible points. The weight of the Improvement Activity performance category is 15%. Thus 40/40 x 15 = 15 points toward the total MIPS score.
**Combined with the 5 point bonus for small practices and/or performance in other categories, the solo practitioner could earn points toward a MIPS payment bonus**
A group of 26 MIPS-eligible physicians attests to two activities: 1 medium-weighted activity and 1 high-weighted activity. The group would receive 30 points for the Improvement Activities performance category, which is weighted 15% of the total MIPS composite score. This performance alone does not meet the 15 point performance threshold for 2018, and could result in a payment reduction in 2020 without submitting additional performance data in other MIPS performance categories.
(1 medium-weight activity X 10 points) + (1 high-weight activity X 20 points) or 30 out of 40 possible points. The weight of the Improvement Activity performance category is 15%. Thus 30/40 x 15 = 11.25 points toward the total MIPS score.