Wednesday, June 29, 2016

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Read the latest medical news for the San Bernardino County area.


Noridian begins deactivation of providers who failed to revalidate

The due date for physicians to revalidate their Medicare enrollment information has passed for the most recent cycle of physician revalidation required by the Centers for Medicare and Medicaid Services (CMS). Physicians who received a revalidation notice from Noridian, CMS’ Medicare contractor for California, and who did not turn in a completed application to CMS prior to the May 31 deadline, will have their Medicare billing privileges deactivated.

If you are deactivated for failure to respond to a revalidation notice, you must submit a reactivation application. The date of receipt of the reactivation application will be the new effective date for Medicare billing privileges. 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, the provider will be revalidated and no further action is needed.

If you do not know if you received a notice, you can look up your revalidation date through the CMS look-up tool. Those due for revalidation in the near future will display a revalidation due date. All other providers/suppliers will see "TBD" in the due date field.

For more information on the revalidation process, see MLN Matters #SE1605.

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

Reminder: CMS meaningful use hardship exception deadline is July 1

Physicians should be aware that July 1, 2016, is the extended deadline for physicians to file hardship exception applications from the electronic health record incentive program meaningful use requirements.

In mid-December 2015, Congress adopted a last-minute bill that gave the Centers for Medicare and Medicaid Services (CMS) the authority to grant a blanket exception for all eligible physicians who applied for an exception from the 2015 meaningful use penalties.

CMS reports the extension is being granted “so providers have sufficient time to submit their applications to avoid adjustments to their Medicare payments in 2017."

CMS also released new “streamlined” hardship exception application forms “that reduce the amount of information that eligible professionals must submit to apply for an exception,” the agency said. The new application forms and instructions on filing a hardship exemption are on the CMS website.

To help physician members navigate the hardship exemptions process, the California Medical Association (CMA) has published “Meaningful Use Hardship Exception Frequently Asked Questions.” This document answers questions about the blanket exemption, including who should apply, deadlines and more.

This free members-only resource is available in CMA's online resource library.


DHCS suspends planned passive enrollment for duals project

The Department of Health Care Services (DHCS) announced last week that it would not move forward with its planned annual passive enrollment of dual eligible beneficiaries under the Coordinated Care Initiative (CCI) after it received feedback from the California Medical Association (CMA) and 40 other stakeholders asking the agency to pursue enrollment strategies that support voluntary "opt-in" enrollment.

Instead, DHCS said it will implement a voluntary "opt-in" enrollment effort beginning in July 2016. The new streamlined enrollment strategy will include mandatory Managed Medi-Cal Long-Term Supports and Services (MLTSS) plan enrollment. DHCS said it would monitor participation in the program; should voluntary enrollment not prove to be a viable option for program sustainability, passive enrollment remains an option in the future.

In April, DHCS released a series of proposals that would have changed the CCI enrollment process to 1) passively enroll beneficiaries into Cal MediConnect; and to 2) streamline enrollment by allowing plans to eliminate or dramatically reduce the role of the enrollment broker.

CMA, in partnership with Justice in Aging and other patient advocacy groups, signed a joint letter strongly opposing the proposals.

“Experience shows that passive enrollment strategies result in high opt-out rates, confusion, disruption in care, distrust of managed care and high costs to plans,” the letter to DHCS said. “(P)assively enrolling over 100,000 beneficiaries in a two-month period is staggering. The plans, HICAPs, Ombudsman, enrollment broker, and the broader community lack the capacity to meet the needs of the affected beneficiaries, especially on the expedited timeline DHCS has proposed, under which the first set of notices would be mailed to beneficiaries.”

The Coordinated Care Initiative was authorized by the state in July 2012 in an effort to save money and better coordinate care for the state’s low-income seniors and persons with disabilities. The program began with a three-year demonstration project that expected to see a large portion of the state's dual eligible beneficiaries transition to managed care plans.

Although the state is not going forward with passive enrollment in 2016, DHCS has stated they are still considering a passive enrollment strategy for 2017.

Click here to read CMA's letter to DHCS on this issue.

For more about the duals program, visit www.cmanet.org/duals.

Contact: Lishaun Francis, (916) 551-2554 or lfrancis@cmanet.org.


Maintaining your Medicare opt-out status

Physicians who intend to opt-out, or who have previously opted-out of Medicare, should be aware of changes to the Medicare opt-out period as a result of the Medicare Access and CHIP Reauthorization Action of 2015 (MACRA).  

Validated opt-out affidavits signed on or after June 16, 2015, will automatically renew every two years. Previously, physicians who opted out of the program would have to renew their affidavit every two years to maintain their opt-out status. Under the new rules, affidavits will automatically renew every two years unless the physician cancels in writing with at least 30 days notice prior to the start of the next two-year opt-out period. Cancellation notices must be sent to all Medicare contractors with which they filed their original affidavits.

Opt-out affidavits signed prior to June 16, 2015, will expire two years after the effective date. If you have an opt-out affidavit signed prior to June 16, 2015, and you wish to extend your opt-out period, you must submit an opt-out renewal affidavit to Noridian (California’s Medicare contractor) no later than 30 days after the current opt-out expiration date. Subsequent renewals will happen automatically every two years per the new rules.

More information about opting out and maintaining opt-out status is available here.


CMS releases draft MACRA regulations

The Centers for Medicare and Medicaid Services (CMS) on Wednesday released a 962-page proposed rule that lays out the agency's plan for implementing last year's groundbreaking Medicare reform law, the Medicare Access and CHIP Reauthorization Act (MACRA).

Ahead of CMS’ release of the rule, physician leaders testified before the U.S. House of Energy and Commerce Committee’s Subcommittee on Health during a special MACRA hearing last week. The physicians expressed cautious optimism and said the law represents a critical opportunity to enhance flexibility and innovation in health care that can lead to improved care and better outcomes for patients, but the law also needs to allow physicians to focus on practicing medicine by aligning and simplifying quality reporting programs.

“MACRA makes significant improvements over the current system, including the repeal of the flawed sustainable growth rate formula and giving the Centers for Medicare and Medicaid Services an opportunity to reset and improve performance measurement as well as other requirements,” said Barbara McAneny, M.D., immediate past chair of the American Medical Association (AMA) Board of Trustees, who testified at the hearing. “By increasing the availability of alternative payment models, CMS will spur innovative delivery models focused on enhanced care coordination that can lead to better outcomes for patients.”

The proposed regulations
While there has not yet been time to digest and dissect the entire 962-page regulation, initial reviews indicate that CMS has listened to the input provided by the California Medical Association (CMA), AMA and others in organized medicine over the past year. Since MACRA was passed last spring, organized medicine has been providing extensive physician feedback on MACRA implementation.

Among other issues, the proposed rule addresses questions about elements of MACRA's Merit-Based Incentive Payment System (MIPS), including:

Quality: Clinicians would choose six measures to report, rather than the current requirement of nine, from among a range of options that accommodate differences among specialties and practice settings.

Advancing care information: Clinicians would be able to choose customizable measures that reflect how they use technology in their day-to-day practice. Unlike the existing meaningful use program, this category would not require all-or-nothing electronic health record measurement or redundant quality reporting.

Clinical practice improvement activities: Physicians would be rewarded for clinical practice improvements, such as activities focused on care coordination, patient engagement and patient safety. Clinicians would select activities that match their practices’ goals from a list of more than 90 options.

CMA and AMA will continue to work closely with CMS as the agency revises the regulations over the coming months.


Physicians show cautious optimism for MACRA during Capitol Hill meeting

Physician leaders expressed cautious optimism for the landmark Medicare payment reform law (known as MACRA) during a key congressional committee hearing on April 19. The physicians said the law represents a critical opportunity to enhance flexibility and innovation in health care that can lead to improved care and better outcomes for patients, but the law also needs to allow physicians to focus on practicing medicine by aligning and simplifying quality reporting programs.

“MACRA makes significant improvements over the current system, including the repeal of the flawed sustainable growth rate formula and giving the Centers for Medicare and Medicaid Services (CMS) an opportunity to reset and improve performance measurement as well as other requirements,” said Barbara McAneny, M.D., immediate past chair of the American Medical Association Board of Trustees. “By increasing the availability of alternative payment models, CMS will spur innovative delivery models focused on enhanced care coordination that can lead to better outcomes for patients.”

Dr. McAneny was one of four physicians who spoke at a hearing of the U.S. House Energy and Commerce Committee’s Subcommittee on Health. Together, they highlighted the three necessary steps to ensure MACRA’s successful implementation:

  • Consolidating performance reporting. The new regulations will need to move away from the current pass-fail programs to accommodate the needs of all practices, specialties and patient populations. CMS also will need to streamline the existing burdensome reporting requirements and improve the timing of feedback reports for physicians.

  • Broadening alternative payment models. MACRA regulations must establish a clear pathway for rapid approval and implementation of physician-focused alternative payment models that establish different approaches to delivering patient care. CMS must also avoid adding burdensome requirements that cause resources to be spent on administrative costs rather than helping patients.

  • Improving measurement. The physicians pointed to needed improvements including elimination of the program flaws that make practices with high-risk patients more susceptible to penalties; timely data reports; and suitable methods for attribution and resource use.
"Currently, physicians view measurement as burdensome, inaccurate, and often outdated," said Dr. McAneny. Reporting requirements are extremely costly, she said, with estimates finding that practices spend more than 750 hours per physician annually to report quality measures, with an associated price tag of more than $15.4 billion per year nationwide. Dr. McAneny also said quality measurement reporting and data requirements should be standardized across payor type to avoid duplication.

The other physicians testifying at the hearing agreed on the great potential of MACRA if it is thoughtfully implemented based on physician feedback.

“We believe that the work needed to bring about the change in how physicians provide medical care that will make MACRA successful will mean better care for patients, better professional experience for physicians and their medical teams, and better control of health care costs,” said Robert Wergin, M.D., chair of the American Academy of Family Physicians' Board of Directors.

CMS’ proposed regulations are expected this spring

CSU and palliative care coalition launch eduction programs on advance care planning and billing

In response to the nation’s growing demand for physicians trained in advance care planning conversations, the California State University Institute for Palliative Care has partnered with the Coalition for Compassionate Care of California to co-design a comprehensive continuing education curriculum for health care professionals.

New this year, Medicare providers can be reimbursed for advance care planning conversations with patients. The newly implemented reimbursement provides an impetus for clinicians to spend time exploring patient health care preferences and documenting goals of care.

“Patients want to have these conversations with their providers, and providers need to be paid for the time a meaningful conversation requires,” said Helen McNeal, executive director of the CSU Institute for Palliative Care. “The problem is that clinicians haven’t learned how to talk about advance care planning with patients, and their billing departments don’t know how to use the new billing codes.”

The new online curriculum, "Effective Advance Care Planning: Skills Building for the Entire Organization," provides detailed information about the critical components of advance care planning and billing in an accessible, cost-effective format. Due to their online format, health care professionals from around the country can take the courses at a time and place convenient to them.

Starting this May, the following self-paced courses will be open for registration:

  • Effective Advance Care Planning Fundamentals
  • Facilitating an Advance Care Planning Conversation
  • Building Engagement with Advance Care Planning
  • Billing for Advance Care Planning Conversations
“Reimbursement for advance care planning is a game changer,” said Judy Thomas, CEO of the Coalition for Compassionate Care of California. “Advance care planning is an essential component of patient-centered, quality health care. Professionals with advance care planning expertise are able to identify and clarify individuals’ choices regarding medical treatment.”

For more information, click here.


CMA opposes proposed changes to duals demonstration

The Department of Health Care Services (DHCS) recently released a series of proposals that would change the Coordinated Care Initiative (CCI) enrollment process to 1) passively enroll beneficiaries into Cal MediConnect; and to 2) streamline enrollment by allowing plans to eliminate or dramatically reduce the role of the enrollment broker.

The California Medical Association (CMA), in partnership with Justice in Aging and other patient advocacy groups, signed a joint letter strongly opposing the proposals.

The Coordinated Care Initiative was authorized by the state in July 2012 in an effort to save money and better coordinate care for the state’s low-income seniors and persons with disabilities. The program began with a three-year demonstration project that expected to see a large portion of the state's dual eligible beneficiaries transition to managed care plans.

Experience shows that passive enrollment strategies result in high opt-out rates, confusion, disruption in care, distrust of managed care and high costs to plans.

"These strategies simply do not work," the letter said. "The proposed enrollment changes ignore lessons learned from implementation thus far, and require substantial resources from DHCS, the plans, the enrollment broker and the stakeholder community to implement – resources that should be leveraged on improving the quality of the program and the beneficiary experience and thus promote retention."

Throughout the development of the Coordinated Care Initiative, DHCS and the Centers for Medicare and Medicaid Services (CMS) repeatedly promised to protect beneficiaries through the complicated transition into managed care. Yet, DHCS and CMS moved forward with program implementation, ignoring stakeholder recommendations to slow down and conduct additional systems testing. As a result, beneficiaries experienced significant disruption and confusion, and anticipated enrollment goals were not met.

Today, two years into implementation, health plans are just starting to deliver the coordination of benefits promised under this new delivery model. The enrollment proposals ignore DHCS’s own evaluation data and threaten to revert CCI back to the enrollment chaos of early implementation.

Click here to read the letter.

For more about the duals program, visit www.cmanet.org/duals.


CMS announces new primary-care payment and health care delivery model

The Centers for Medicare and Medicaid Services (CMS) this week announced a new payment model aimed at transforming and improving how primary care is delivered and paid for in America. The Comprehensive Primary Care Plus (CPC+) model will be implemented in up to 20 regions and can accommodate up to 5,000 practices, which would encompass more than 20,000 doctors and clinicians and the 25 million people they serve. The initiative is designed to provide doctors the freedom to care for their patients the way they think will deliver the best outcomes and to pay them for achieving results and improving care. It builds on the current Comprehensive Primary Care program.

"Strengthening primary care is critical to an effective health care system," said Dr. Patrick Conway, CMS deputy administrator and chief medical officer. "By supporting primary care doctors and clinicians to spend time with patients, serve patients’ needs outside of the office visit, and better coordinate care with specialists we can continue to build a health care system that results in healthier people and smarter spending of our health care dollars. The Comprehensive Primary Care Plus model represents the future of health care that we’re striving towards."

The program is a five-year program that will begin in January 2017. It may also qualify as an alternative payment model under MACRA beginning in 2019.

According to CMS, clinicians will be able to participate in two ways. In Track 1, clinicians will receive a monthly care management fee for specific services. That fee is in addition to the fee-for-service payments under the Medicare Physician Fee Schedule for care.

Track 2, is a hybrid payment design that will allow practices to receive payment for monthly care management and, instead of full Medicare fee-for-service payments for evaluation and management services, they will receive reduced Medicare fee-for-service payments and up-front bundled comprehensive primary-care payments. This plan will allow greater flexibility in how practices deliver care outside of the traditional face-to-face encounter, the agency said.

Physicians in both tracks can receive upfront incentive payments that they might have to repay if they do not perform well on quality and utilization metrics. Payment reductions for poor performers could be as high as 14 percent.

"At first glance, this new payment model initiative includes several advances over the current primary care model, particularly because it emphasizes improvements in care that are achievable by primary care physicians instead of cost reductions that are beyond their control," said Dr. Steven J. Stack, M.D., president of the American Medical Association.

"We look forward to reviewing the proposal in detail and working constructively with CMS to ensure physicians have flexible and workable payment models that support high-quality patient care and put less administrative burden on physician practices to alleviate physician burnout."

CMS is expected to announce the CPC+ regions in July.

For questions about the payment model and solicitation process, please visit the Comprehensive Primary Care Plus web page or email CPCplus@cms.hhs.gov.

CMS is also hosting two webinars about the initiative open to all interested stakeholders.  To register, click on the links below.

Thursday, April 14, 3 - 4 p.m. EDT
Tuesday, April 19  |  3 - 4p.m. EDT



CMS announces second cycle of Medicare revalidation

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, the Centers for Medicare and Medicaid Services (CMS) is initiating a second cycle of revalidation requests.

According to CMS, Medicare Administrative Contractors (MAC) – Noridian in California – will continue to send revalidation notices two or three months prior to each provider’s revalidation due date.

What providers need to know:

  • If you have multiple reassignments/billing structures, you must coordinate the revalidation application submission with each entity.

  • MACs will send revalidation notices (either by email or mail) two or three months prior to the revalidation due date. When responding to revalidation requests, be sure to revalidate your entire Medicare enrollment record, including all reassignment and practice locations.

  • If a revalidation application is received but incomplete, your MAC will contact you for the missing information. If the missing information is not received within 30 days of the request, the MAC will deactivate your billing privileges.

  • If billing privileges are deactivated, a reactivation will result in the same Provider Transaction Access Number, but there will be an interruption in billing during the period of deactivation. This will result in a gap in the provider’s enrollment status with Medicare.

  • If the revalidation application is approved, the provider will be revalidated and no further action is needed.
Providers can now look up an individual provider or organization to find their revalidation date through CMS’ look-up tool. Those due for revalidation in the near future will display a revalidation due date. All other providers/suppliers will see "TBD" in the due date field.

For more information on the revalidation process, see MLN Matters #SE1605.

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


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