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MACRA final rule exempts one-third of Medicare physicians from MIPS

Nearly a third of Medicare physicians could be exempt from Medicare's new merit-based incentive payment system (MIPS) under the final rule implementing the Medicare Access and CHIP Reauthorization Act (MACRA). The rule was released today by the Centers for Medicare and Medicaid Services (CMS).

In the final rule, CMS raised the low-volume threshold, so that providers with less than $30,000 in Medicare payments or fewer than 100 Medicare patients are exempt from the MIPS reporting requirements. The earlier proposed rule would only have exempted physicians with less than $10,000 in Medicare payments.

Other key highlights of the final rule include:

  • Restores the 0.5 percent payment update for 2017
  • Reduces by half the number of measures that physicians must report, from 30 to 15.
  • Lets physicians pick their pace of participation, and will not penalize physicians who at least attempt to report on a few measures
  • Only requires physicians to report for 90 days in 2017 to receive a bonus
  • Providers will not be scored on "resource use" (physician cost) in 2017
  • Mostly eliminates the pass/fail system and will provide proportional credit.
  • Expands the types of alternative payment models (APM) that can participate in MACRA, most notably Track 1 ACOs. The final rule also reduces the financial risk requirements for APMs.
Today’s final rule reflects additional steps taken by CMS to reduce the regulatory burden on physicians, but concerns remain. Physicians already spend 785 hours a year on quality reporting activities. For every hour physicians provide direct clinical face time with patients, nearly two additional hours are dedicated to paper and desk work.

“Physicians, particularly small and rural practices, need flexible and streamlined systems to support the high-quality patient care we provide,” said California Medical Association (CMA) President Steve Larson, M.D., MPH. “From day one, CMA urged CMS to delay the MACRA reporting period and provide a longer transition timeline for small medical practices and exempt them from penalties. We applaud today’s announcement, and we appreciate that CMS will offer full participation and bonus payment eligibility to medical practices ready for MACRA on January 1, 2017.”

It is clear that CMS listened to physicians. The final rule is a vast improvement over current law and the initial proposed rule.

The final rule is nearly 2,400 pages – the result of a CMS listening tour with nearly 100,000 attendees and 4,000 public comments.

“CMA is reviewing and assessing the impact of the complex rule,” said Dr. Larson. “We remain committed to ensuring that MACRA allows more innovative, physician-led alternative payment models and lessens the reporting burdens on everyone.”

For a summary of the final MACRA rule, visit https://qpp.cms.gov.

Physicians can also visit CMA’s MACRA resource center to better understand the payment reforms and access resources to help with the transition. The center is a one-stop-shop with tools, checklists and information from CMA, CMS, AMA and national specialty society clinical data registries. CMA will add an updated summary and materials, including additional webinars, to the resource center in the coming weeks.

View the CMA resource center at www.cmanet.org/macra.

California Medical Association responds to final MACRA implementation rule

The Centers for Medicare and Medicaid Services (CMS) today released the final implementation rule for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which aims to reform the Medicare physician payment system.

The California Medical Association (CMA), American Medical Association (AMA) and nearly every other physician organization supported the bipartisan legislation because it was intended to provide stable payment updates, significantly reduce the quality reporting program burdens, reinstate bonus payments and allow innovative, physician-led alternative payment models.

“Physicians, particularly small and rural practices, need a modernized, flexible and streamlined system to support high-quality patient care,” said CMA President Steven E. Larson, M.D., MPH. “From day one, CMA urged CMS to delay the MACRA reporting period and provide a longer transition timeline for small medical practices, as well as exempt them from penalties. We applaud today’s announcement, which included additional exemptions and the elimination of penalties during the first year of implementation even for physicians that attempt to report on a few measures, as well as the delay in the 2017 reporting period. We also appreciate that CMS will offer full participation and bonus payment eligibility to medical practices ready for MACRA on January 1, 2017.”

Today’s final rule reflects additional steps taken by CMS to reduce the regulatory burden on physicians, but concerns remain. Physicians already spend 785 hours a year on quality reporting activities. For every hour physicians provide direct clinical face time with patients, nearly two additional hours are dedicated to paper and desk work.

“CMA is reviewing and assessing the impact of the complex final rule,” said Dr. Larson. “We remain committed to ensuring that MACRA allows more innovative, physician-led alternative payment models and lessens the reporting burdens on everyone.”

Physicians should visit CMA’s MACRA resource center to better understand the payment reforms and access resources for the transition. The resource center is a one-stop-shop with tools, checklists and information from CMA, CMS, AMA and national specialty society clinical data registries. The final rule is nearly 2,400 pages – the result of a CMS listening tour with nearly 100,000 attendees and 4,000 public comments. CMA will add an updated summary and materials, including additional webinars, to the resource center in the coming weeks.

TWEET THIS NEWS

.@cmaphysicians applauds CMS for including additional exemptions/eliminating penalties in 1st year of implementation http://cal.md/2dPZLoJ

.@cmaphysicians remains committed to ensuring #MACRA allows more innovative/physician-led alternative payment models http://cal.md/2dPZLoJ

“Physicians need a modernized, flexible and streamlined system to support high-quality patient care.” @cmaphysicians http://cal.md/2dPZLoJ

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The California Medical Association represents the state's physicians with more than 42,000 members in all modes of practice and specialties. CMA is dedicated to the health of all patients in California. For more information, please visit cmanet.org, and follow CMA on Facebook, Twitter and YouTube.

AMA introduces new MACRA payment model evaluator

The American Medical Association (AMA) has introduced a new online tool to help physicians evaluate the various new Medicare payment models and improve their opportunities for success under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which will go into effect in 2017.

The AMA Payment Model Evaluator is a free interactive tool offering initial assessments to help physicians determine how their practices will be impacted by MACRA. Once physicians or medical practice administrators fill out the online questionnaire, they will receive guidance on participating in the MACRA payment model that is best for them. They will also receive relevant educational and actionable resources.

To help physicians understand the MACRA payment reforms, and what they can do now to start preparing for the transition, the California Medical Association (CMA) has created a MACRA resource center. There you will find an overview of MACRA, and a comprehensive list of tools, resources and information from CMA, AMA and the Centers for Medicare and Medicaid Services.

View the CMA resource center at www.cmanet.org/macra.

Podcast series: Inside Medicare's new payment system

Changes to the Medicare payment system are on the horizon, and physicians around the country are wondering how the new Medicare Access and CHIP Reauthorization Act (MACRA) will impact their practices. The American Medical Association (AMA) and ReachMD have produced a podcast series to provide physicians with an inside look at what’s to come and what they can do now to prepare for the transition to MACRA.

Hear from industry experts and physician leaders about their experiences with new payment models, quality reporting and more. Available episodes include:

  • Implementing MACRA: The AMA’s Keys to Advancing Opportunities, Avoiding Pitfalls
  • APMs in Cancer Care: The Patient-Centered Oncology Payment Model
  • The Rise of Specialist-Driven Alternative Payment Models in American Medicine
  • Thoughts on Physician Advocacy and Payment Reform with AMA President Andrew Gurman, M.D.
  • The Future of Medicare Payment Reform: Perspectives on MACRA with CMS's Andy Slavitt
To listen to the podcasts, click here.

More MACRA resources

To help physicians understand MACRA payment reforms, and what they can do now to start preparing for the transition, the California Medical Association (CMA) has published a MACRA resource center.

There you will find an overview of MACRA, and a comprehensive list of tools, resources and information from CMA, AMA and the Centers for Medicare and Medicaid Services.

View the resource center at www.cmanet.org/macra.

Physicians encouraged to verify CHPI data by November 11

Earlier this month, approximately 13,000 physicians in California received their individual quality measurement scores for the second cycle of the California Healthcare Performance Initiative System (CHPI) quality rating program. Physicians can review and verify the accuracy of the data used to calculate their scores through the CHPI online portal through November 11, 2016.

The program rates physicians using claims data from Medicare fee-for-service, Anthem Blue Cross, Blue Shield of California and United Healthcare. This claims data includes both commercial and self-funded health plan data from HMO, PPO, POS and Medicare Advantage products.

The individual quality measurement scores were based on claims data for patient care provided January 1, 2012, through December 31, 2014. Physicians were assigned a star rating of one to four stars, based on where they fall as a percentile within a “peer group,” for each measure, as well as a composite score.

Physicians who wish to verify the accuracy of the data used to calculate their scores can do so through the CHPI Review and Corrections portal. To access the review and correction portal, physicians will have to register using their username and registration token – both listed at the top left of each page of the report. Once registered, you will receive a confirmation email with instructions to create a password.

According to CHPI, it will treat the data as complete and accurate if no corrections are made. This means that even if a physician has not logged into the online portal during the review and correction period, CHPI will still publish the physician's data.

Physicians who review their data and identify errors have until November 11, 2016, to report any discrepancies via the CHPI online portal. At the close of the physician review and correction period, discrepancies will be evaluated and corrected, with the results recalculated prior to the public release of the ratings. After November 11, the review and correction period will close, and physicians will be unable to review or report discrepancies.

CHPI has advised the California Medical Association (CMA) that in addition to publishing the ratings publicly, it will also release an aggregated data file to the aforementioned participating plans following the review and correction period later this year. CMA inquired as to how the data would be utilized by the plans, but as of the time of publication, it was not known.

For more information on the CHPI rating methodology, visit the CHPI website at www.chpis.org. CHPI has also published an FAQ on its rating program and a step-by-step review and corrections tutorial.

Physicians who did not receive a letter but would like to confirm whether they are included in CHPI’s rating results can use the CHPI physician lookup at https://provider.medinsight.milliman.com/clients/CHPI/Public/Lookup.

If you have questions or concerns about the CHPI rating results, you may email chpicorrections@pbgh.org and you should receive a response within 48 hours. Physicians who do not hear back within 48 hours or who identify a high volume of discrepancies in the data used to calculate their scores are encouraged to contact CMA at (916) 551-2061 or jwilliams2@cmanet.org.

CMA will also be hosting a webinar on October 5 where CHPI staff will provide an overview of the quality rating project, along with step-by-step instructions on how physicians can review their data for accuracy before the quality scores are published. The webinar is free to CMA members ($99 for non-members). To register, visit the CMA website at www.cmanet.org/events.

CMA urges CMS to recalculate practice expense data to reflect California's higher practice costs

As required by law, at least every three years the Centers for Medicare and Medicaid Services (CMS) adjusts payments under the Medicare physician fee schedule to reflect local differences in practice costs. In the proposed 2017 Medicare physician fee schedule, CMS made nationwide updates to the geographic practice cost indices (GPCI) based on new wage, rent and malpractice expense data.

Unfortunately, according to CMS, the malpractice and practice expense GPCIs went down in nearly every region of California, which would result in a 0.48 percent GPCI payment reduction in all but a few regions of California. The California Medical Association (CMA) is urging CMS to review the data for accuracy, as physician office expenses in California have increased in recent years relative to the rest of the nation.

"California’s real estate market has experienced a remarkable recovery in most regions of the state over the last several years," CMA wrote in comments submitted to CMS last week. "We find it unfathomable that California physicians would be taking a pay cut in 2017 because practice expenses decreased relative to the rest of the nation."

CMA also urged CMS to reconsider the inappropriate weighting of the rent expense category, which was given only an 8 percent weight in the practice expense GPCI. "Office 'rent' is one of the largest and most expensive cost components for physicians, and we would argue that it should be given a much larger weight to more accurately reflect its impact on physician practice expenses," CMA wrote in its comments.

The proposed Medicare payment rule also begins to implement the California "GPCI fix," which will overhaul California’s outdated geographic payment localities. It transitions the payment localities to Metropolitan Statistical Areas, which is consistent with the way Medicare pays hospitals. The localities will be updated annually. This long-overdue fix updating California’s Medicare physician payment regions will raise payment levels for 14 urban California counties misclassified as rural, while holding the remaining rural counties permanently harmless from cuts after 2017. The transition to the new localities starts next year, with the higher locality payments being phased in over a six-year period starting in 2017.

Unfortunately, because of the overall GPCI practice expense and malpractice expense reductions, most California physicians will not see payment increases in 2017. However, without the CMA-led locality change, California physicians would be receiving an even larger payment cut.

CMA has reviewed all of the implementation calculations and provided some minor corrections to ensure that the GPCI fix is implemented accurately. CMA will continue to work closely with CMS on the transition to the new California payment localities.

For more details, including a corrected payment impact chart by locality, see CMA's comments.

Contact: Elizabeth McNeil, (800) 786-4262 or emcneil@cmanet.org.

New CMA resource clarifies prohibitions on balance billing Medi-Medi patients

The California Medical Association (CMA) often receives questions from physician members regarding the ability to collect the 20 percent that Medicare does not cover when the physician is not a Medi-Cal provider, but provides services to Medi-Medi (Medicare/Medi-Cal) patients.

Both state and federal laws provide broad protections to such individuals and prohibit billing a Medi-Cal patient in most circumstances. Running afoul of these laws can put you at risk of a CMS audit and sanctions.

CMA has created a new resource on this topic, “Ask the Expert: Billing Medi-Medi Patients,” free to members at www.cmanet.org/ces.

United Healthcare fails to provide proper notification on rollout of clinical data submission protocol

The California Medical Association (CMA) is concerned that United Healthcare (UHC) failed to properly notify physicians before implementation of its Clinical Data Submission Protocol. Although California law (California Insurance Code §10133.65 and Health & Safety Code §1375.7) requires payors to provide contracted physicians with the 45 business days’ advance notice of any material contracting changes, UHC's only notification to physicians about this new protocol was in its Network Bulletin.

First introduced in 2015, the program originally targeted only Medicare benefit plans and required physicians to submit all laboratory test results for UHC Medicare patients. The expansion of the program will require practices to submit laboratory tests for all UHC Medicaid and commercial benefit plans. UHC has stated, however, that it will help practices establish the transmission method that works best with their current capabilities.

At the request of CMA, UHC delayed the expansion of its Clinical Data Submission Protocol in California. Originally scheduled to take effect July 1, 2016, the expansion was pushed back until September 2. However, CMA believes UHC is not compliant with state law as it has not formally notified all affected physician practices of changes to the protocol. CMA is evaluating its next steps and will update physicians when additional information is available.

While UHC lauds the sharing of clinical patient data as an opportunity to support quality and cost-effective patient care, CMA is also concerned about the administrative burden of the protocol and the impact on physician practices.

For more information about the protocol and requirements for submitting data to UHC, physicians should refer to the updated Clinical Data Submission Protocol Frequently Asked Questions and Methods of Clinical Data Exchange, or contact either the UHC Provider Call Center at (877) 842-3210 or their local UHC Network Account Manager or Provider Advocate.

Click here to view the letter to UHC.

Last chance for some providers to prevent deactivation by Medicare

Noridian, Medicare’s administrative contractor for California, will soon begin deactivating billing privileges for physicians who received revalidation notices from Noridian but have not submitted completed applications to the Centers for Medicare and Medicaid Services (CMS). Last month, Noridian reported that only 19 percent of providers had responded to the most recent Medicare Part B revalidation notices.

Since the passage of the Affordable Care Act (ACA), all Medicare providers and suppliers have been required to revalidate their Medicare enrollment information under new enrollment screening criteria in an effort to prevent fraud within the Medicare system. Once a Medicare enrollment application is validated, the clock starts ticking on a five-year revalidation cycle. Now that five years have passed since the ACA's revalidation requirement took effect, CMS has initiated a second cycle of revalidation requests.

Noridian will send revalidation notices two or three months prior to each provider’s revalidation due date.

The first revalidation due date for this second cycle was May 31, 2016. Effective August 14, 2016, Noridian will deactivate the Medicare billing privileges for affected physicians who failed to complete their revalidation applications CMS prior to the May deadline.

The due date for the second revalidation round was June 30, 2016. Noridian will deactivate billing privileges for physicians who missed the June deadline on September 13, 2016.

To prevent deactivation, the California Medical Association recommends that practices look up their revalidation dates through the CMS look-up tool. If it shows that your practice missed the deadline, you should submit and sign your application online through the PECOS system immediately to prevent deactivation

If you are ultimately deactivated for failure to respond to a revalidation notice, you will be required to submit a reactivation application. The date of receipt of the reactivation application will be the new effective date for your Medicare billing privileges. Noridian will not apply a retroactive effective date, and no payments will be made for the period of deactivation. If a revalidation application is received but incomplete, Noridian will contact you for the missing information. If the missing information is not received within 30 days of the request, Noridian will deactivate your billing privileges.

If your revalidation application is approved, no further action is needed

For more information on the revalidation process, see MLN Matters #SE1605. CMA is also hosting an upcoming webinar on this topic, “Medicare Provider Enrollment: Strategies for Revalidation, Reporting Changes and Avoiding Deactivations,” on Wednesday, August 17 from 12:15 to 1:15 p.m. This webinar will provide guidance on maneuvering the Medicare revalidation and enrollment process. Noridian experts will review how to avoid top errors and other key issues, including finding revalidation due dates, filling out the correct information on enrollment applications, responding to requests for additional information and keeping your enrollment record up to date. This webinar will also review new enrollment tools and tutorials.

If you have questions about the revalidation process, click here or contact Noridian at (855) 609-9960.

CMA publishes MACRA preparation checklist

On April 16, 2015, President Obama signed into law the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), changing the health care financing system in the most significant and far-reaching way since the program's inception in 1965.

To help physicians understand MACRA payment reforms, and what they can do now to start preparing for the transition, the California Medical Association (CMA) has published an important checklist titled, “MACRA: What Should I Do Now to Prepare?

The checklist is available in CMA's MACRA resource center at www.cmanet.org/macra. There you will also find an overview of MACRA, and a comprehensive list of tools, resources and information from CMA, the American Medical Association and the Centers for Medicare and Medicaid Services.

Also available is CMA’s recent webinar, "MACRA: What Is CMA Doing to Improve It? What Steps Can You Take to Prepare Now?" This on-demand webinar is available free to CMA members.