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CMA calls on CMS to reverse step therapy decision

The California Medical Association (CMA) and an American Medical Association (AMA)-led coalition of 94 medical societies delivered a letter to the Centers for Medicare and Medicaid Services (CMS) about the serious concerns physicians have with the agency’s recent decision to allow Medicare Advantage plans to use step therapy for Part B drugs.  The letter calls on CMS to reinstate its 2012 policy prohibiting Medicare Advantage plans from utilizing step therapy protocols for Part B physician administered medications.

The growing burdens generated by step therapy and prior authorization programs create a lengthy process of red tape, multiple phone calls and bureaucratic battles that delay and disrupt patient access to care.

“Step therapy protocols that require patients to try and fail certain treatments before allowing access to other, potentially more appropriate treatments can both harm patients and undercut the physician-patient decision-making process,” the coalition wrote in a letter to CMS Administration Seema Verna, M.D. “The most appropriate course of treatment for a given medical condition depends on the patient’s unique clinical situation and the care plan developed by the physician in close consultation with that patient.”

While CMA and AMA recognize the huge financial burdens on patients and the health care system caused by rising drug prices, it is our hope that another layer of administrative complication will not be added on to an already strained system.

“We recognize the significant difficulty of finding meaningful solutions that have the desired outcome of reducing costs for both,” the letter said. “However, as we work towards finding policies to address this problem, we hope that solutions can be found that do not involve the creation of barriers to appropriate and timely treatment for some of our most critical patients.”

California to begin receiving new Medicare cards in May

The Centers for Medicare and Medicaid Services (CMS) began mailing new identification cards to Medicare beneficiaries this month, as required under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The new cards contain a unique, randomly assigned Medicare Beneficiary Identification (MBI) number that will replace the current SSN-based Health Insurance Claim Number (HICN). The new MBI will also be used for Medicare transactions like billing, and eligibility and claim status checks.

The first wave of cards mailed this month will be to newly-enrolled Medicare beneficiaries. Beginning in May 2018, existing Medicare beneficiaries in California should start receiving their new cards.

CMS will allow a 21-month transition period beginning April 2018, where health care providers will be able to use either the patient’s current Medicare number or the patient’s new MBI number.

CMS has developed a web page to help physicians navigate the transition to the new MBI number, including slides from the most recent CMS Open Door Forum on the transition. Physicians will be able to look up their Medicare patients’ new Medicare Beneficiary Identifier through Noridian, the Medicare Administrative Contractor’s secure web portal starting in June 2018. Physicians should also talk to their practice managers and health IT vendors now to ensure their systems will be ready to accept the MBI.

New Medicare card: Video for your waiting room

To help inform Medicare patients the new Medicare Cards are coming, CMS has created a video for your waiting room. The video tells patients when and how they will receive the new card.

For more information, please visit www.cms.gov/newcard.

CMS now accepting QPP hardship applications for 2017

The Centers for Medicare and Medicaid Services (CMS) is now accepting hardship exceptions from the Medicare Quality Payment Program (QPP) for the 2017 reporting year. Beginning with this reporting year, physicians who do not participate in QPP will see a negative 4 percent payment adjustment in 2019. Physicians who do participate may qualify for bonus payments.

Physicians and groups that qualify for the QPP’s Merit-Based Incentive Payment System (MIPS) can submit a hardship exception application for one of the following reasons:

  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of certified electronic health record technology

If you meet one of the criteria above, you may qualify for a reweighting of the Advancing Care Information performance category score to 0. The 25 percent weighting of the advancing care information category would be reallocated to the quality performance category

There are also some MIPS eligible clinicians who are considered “special status,” who will be automatically reweighted (or exempted in the case of MIPS eligible clinicians participating in a MIPS alternative payment model) and do not need to submit a QPP hardship exception application.

Hardship exception applications can be submitted via the QPP website. You can also contact the QPP Service Center at (866) 288-8292 or QPP@cms.hhs.gov and work with a representative to submit an application.

Once an application is submitted, you will receive a confirmation email that your application was received and is pending, approved or dismissed. Applications will be processed on a rolling basis.

Physicians should also be aware that 2017 is a transition year, with CMS offering “pick your pace” options for participation. Participating at any level in 2017 will ensure that you will not be hit with payment penalties in 2019. The most lenient participation option would allow physicians to simply "test" the program to ensure that their systems are working and that they are prepared for broader implementation in 2018 and beyond. While physicians who choose this option will not receive bonus payments, they will avoid a negative penalty.

Providers with less than $30,000 in Medicare payments or fewer than 100 Medicare patients are exempt from the MIPS reporting requirements. Physicians who exceed this threshold are subject to MIPS and are encouraged to participate in MIPS for the 2017 transition year to avoid the negative payment adjustment. If you are unsure of your MIPS participation status, click here.

California physicians in practices of 15 or fewer can receive free assistance to prepare and participate in Quality Payment Program through CalHIPSO. For more information visit www.hsag.com/CalHIPSO.

The American Medical Association has also published a short instructional video to help physicians avoid being penalized under the QPP. The video offers step-by-step instructions on how to report on one patient for one measure to avoid a negative 4 percent payment penalty in 2019.

For more information about the QPP, implemented with the Medicare Access and CHIP Reauthorization Act (MACRA), visit www.cmanet.org/macra.

CMS dedicates new webpage to Medicare Beneficiary Identification number change

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires the Centers for Medicare and Medicaid Services (CMS) to remove Social Security numbers from Medicare cards to prevent identity theft. CMS has said it will in 2018 begin issuing new Medicare cards that replace the current identification number—which is the beneficiary's Social Security Number—with an all-new Medicare Beneficiary Identification (MBI) number.

CMS has developed a new webpage to help physicians navigate the transition to the new MBI number, including a recently developed resource on how to talk to your Medicare patients about the new Medicare card. Physicians should also talk to their practice managers and health IT vendors now to ensure their systems will be ready to accept the MBI.

What can physicians do now to prepare?

Identify your patients who qualify for Medicare under the Railroad Retirement Board (RRB). You will no longer be able to distinguish RRB patients by the number on the new Medicare card. You will be able to identify them by the RRB logo on their card and a unique message on the eligibility transaction response. The message will say, "Railroad Retirement Medicare Beneficiary" in 271 Loop 2110C, Segment MSG. If you use the number only to identify your RRB patients beginning in April 2018, you must identify them differently to send Medicare claims to the RRB Specialty Medicare Administrative Contractor, Palmetto GBA.

Ensure your practice management system is ready to accept the new MBI numbers. Beginning in October 2018, through the transition period, CMS will return your patient's MBI on every electronic remittance advice for claims you submit with a valid and active HICN. It will be in the same place you now get the "changed HICN": 835 Loop 2100, Segment NM1 (Corrected Patient/Insured Name), Field NM109 (Identification Code). Practices will need to ensure their system is prepared to accept the new format and length of the new ID numbers.

CMS to issue MIPS participation status notices

Starting in late April, the Centers for Medicare & Medicaid Services (CMS) began notifying physicians whether they will be subject to Medicare's new Merit-Based Incentive Payment System (MIPS). MIPS is part of the new Medicare Quality Payment Program established under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Providers with less than $30,000 in Medicare payments or fewer than 100 Medicare patients are exempt from the MIPS reporting requirements. Physicians who exceed this threshold are subject to MIPS and are encouraged to participate in MIPS for the 2017 transition year to avoid a negative payment adjustment.

Over the next month, physicians will be receiving letters from CMS informing them if they, or the individuals in their group, are exempt from MIPS. The letter also advises physicians to review their information and determine whether they plan to participate as an individual physician or as a group, how to avoid a penalty or possibly earn a positive adjustment, and includes an FAQ with additional information. For clinicians participating under multiple TINs, a separate notification will be sent to reflect each TIN.

If you did not receive a letter, you can confirm your participation status using the CMS MIPS participation lookup tool

Physicians can visit the California Medical Association (CMA) 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, the American Medical Association and national specialty society clinical data registries. View the CMA resource center at www.cmanet.org/macra or visit the CMS Quality Payment Program website for more information.

Open Payments review and dispute period open

Drug and medical device manufacturers have completed their submission of data to the Open Payments system on payments or transfers of value made to physicians during 2016. Physicians now have 45 days to review and dispute records attributed to them. The review and dispute period is open until May 15, 2017. The review and dispute process is voluntary, but encouraged.

The Centers for Medicare and Medicaid Services (CMS) will publish the 2016 payment data, along with updates to the 2013 and 2014 data, on June 30, 2017. Disputes that are initiated before the May 15 deadline will be flagged in the public release on June 30.  

Under the Sunshine Act, drug and medical device manufacturers are required to report their financial interactions with licensed physicians – including consulting fees, travel reimbursements, research grants and other gifts. Any payments, ownership interests and other “transfers of value” are reported to CMS for publication in the online database.

Physicians who are not already registered should be aware that there is a two-step process to register for the Open Payments program. The first step requires physicians to register at the CMS Enterprise Identity Management System portal, a step many physicians may have already completed as the gateway enables access to a number of other CMS programs. Step two is to register in CMS’ Open Payments system.

Physicians who have already registered but who have not accessed their account in the past 60 days will need to unlock their account by going to the CMS Enterprise Portal, which will prompt you to enter your user ID and correctly answer all challenge questions. You will then be prompted to enter a new password.

Users who registered last year, but who have been inactive for more than 180 days, will need to reactivate their account by contacting the Open Payments Help Desk at openpayments@cms.hhs.gov or (855) 326-8366.

CMS delays reporting deadline for physician labs

The Centers for Medicare and Medicaid Services (CMS) has announced that it will delay the deadline for physician office-based laboratories to meet new reporting requirements. Qualified laboratories now have until May 30, 2017, to complete reporting of private payor payment data for clinical testing services, as required by the Protecting Access to Medicare Act (PAMA).

Under PAMA, laboratories that meet revenue thresholds are required to report private payor payment rates and associated volumes for tests they perform that are paid on the Clinical Laboratory Fee Schedule (CLFS). CMS said it will use data collected to set new payment rates for these tests, a move that is expected to result in decreased reimbursement for these services. 

In an effort to preserve point-of-care testing and to stave off the decrease in rates, the American Medical Association (AMA) sent a letter requesting a one-year delay in the implementation of the new CLFS and that CMS work with the physician community to find an appropriate path forward that would preserve point-of-care testing in physician office-based laboratories. The California Medical Association supports AMA’s actions.

More information on the announcement by CMS and the PAMA reporting requirements are available on the CMS website.

Meaningful use reporting deadline pushed back two weeks to March 13

The Centers for Medicare & Medicaid Services (CMS) on Monday announced that physicians would have two additional weeks to register and attest to meaningful use for 2016 and avoid the 2018 penalty. Physicians now have until Monday, March 13, to attest for the 2016 reporting year. Two weeks ago, hospitals also received a similar reprieve.

Physicians should note that CMS is only extending the attestation period, not the reporting period, so physicians must have concluded their reporting by December 31, 2016.

Although the Medicare meaningful use program is being phased out this year, physicians are still required to report meaningful use measures for 2016 to avoid a 3 percent Medicare penalty in 2018. According to CMS, approximately 171,000 physicians are expected to be penalized this year because they didn't attest to meaningful use for 2015.

Medicare meaningful use reporting will end in 2017, with eligible clinicians who do not participate in the new advanced alternative payment models transitioning to Medicare's new Merit-Based Incentive Payment System (MIPS).

To attest, providers should submit their data through the CMS registration and attestation system. Physicians may select an EHR reporting period of any continuous 90 days from January 1, 2016, through December 31, 2016.

CMA recommends that physicians attest during off-peak hours, such as evenings and weekends, to speed up the attestation process. Physicians are also urged to take time now to ensure that their Medicare enrollment information is up-to-date before entering their 2016 attestation data. Review the CMS Registration and Attestation Resources Page for other tips to success.

Please note the deadline referenced above only applies to the Medicare EHR program, not the Medicaid (Medi-Cal in California) program. For more details on the Medi-Cal program and deadlines, see http://medi-cal.ehr.ca.gov.

2017 Medicare EHR payment adjustment reconsideration forms due February 28

Eligible physicians who have been identified as being subject to Medicare electronic health record (EHR) payment penalties in 2017 (based on the 2015 reporting period), and believe that determination to be in error, have until February 28, 2017, to submit a reconsideration form to the Centers for Medicare and Medicaid Services (CMS).

The reconsideration form can be downloaded from the CMS website. For reconsideration instructions, click here. If you have questions about the reconsideration process, please email pareconsideration@provider-resources.com.

For more information on payment adjustments and hardship applications, or for information on reporting requirements, please visit the CMS EHR Incentive Programs web page.
 



Are you exempt from ICD-10 PQRS penalties in 2016?

On October 1, 2016, new ICD-10 code sets went into effect that will impact the ability of the Centers for Medicare and Medicaid Services (CMS) to process data reported on certain quality measures for the fourth quarter of 2016. Because of this, CMS announced that it will waive 2017 or 2018 Physician Quality Reporting System (PQRS) payment adjustments, if applicable, for any physician or group practice that fails to satisfactorily report for 2016 solely as a result of the impact of ICD-10 code updates on quality data reported for the fourth quarter of 2016.

  • Diabetes
  • Cataracts
  • Oncology
  • Cardiovascular Prevention
  • Diabetic Retinopathy
The 2016 reporting deadline is February 28, 2017.

Click here to read the CMS FAQ on the ICD-update and its impact on PQRS.