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Read the RheumWATCH archives on topics such as rheumatology advocacy, policy updates, insurance advocacy, and practice management.
On November 17, the ACR submitted comments to CMS in response to the agency’s Request for Information (RFI) on the implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which repealed the SGR and outlined new Medicare payment systems.
In the comments, ACR President Joan Von Feldt, MD, responded to specific questions in the RFI and provided the following overall recommendations for CMS in implementing MACRA:
On October 1, 2015, CMS issued an RFI seeking stakeholder input on how it should implement reforms enacted under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Specifically, the RFI solicited input on the implementation of select provisions of MACRA, including aspects of the Merit-Based Incentive Payment System (MIPS), developing and promoting alternative payment models (APMs), and encouraging creating physician-focused payment models (PFPMs).
MACRA repealed the broken Sustainable Growth Rate (SGR) payment system and set in motion policy that will be more fundamentally changing to rheumatologists and rheumatology practices than the Affordable Care Act. MACRA puts in place a five-year period of small, stable updates followed by implementation of the Merit-Based Incentive Payment System (MIPS). MIPS, with payment adjustments beginning in 2019, includes a combination of Meaningful Use, Value-Based Modifier, and PQRS programs, and adds a Clinical Practice Improvement component.
The MIPS will apply to “eligible professionals” beginning in 2019. CMS will develop a methodology for assessing each physician’s overall performance in four categories:
Physicians will receive a composite score for each performance period, which will be compared to a performance threshold defined in advance. Depending on whether their composite score falls above or below the performance threshold, physicians will receive a positive or negative adjustment to their Part B payments under the PFS. For 2019, the MIPS adjustment will be plus or minus 4%, and will increase to plus or minus 9% by 2022. Physicians who are “exceptional” performers are also eligible for an additional bonus payment.
Providers accepting Medicare will have no choice but to participate in the MIPS program or join an alternative practice model such as an Accountable Care Organization. MACRA includes provisions that are designed to encourage both the development of and physician participation in Alternative Payment Models (APMs), such as Accountable Care Organizations (ACOs) and bundled payment arrangements. Most importantly, MACRA provides CMS significant leeway to implement many aspects of the value-based adjustments. CMS intends to use the feedback received in response to the RFI to develop policies related to the MIPS and APM incentive payments, which go into effect beginning January 1, 2019.
Send your questions about MACRA to the ACR at firstname.lastname@example.org.
CMS has extended the informal review period for 2014 PQRS reporting to December 16, 2015. All professionals who believe they have been incorrectly assessed a penalty for 2014 reporting now have until midnight on December 16, 2015 to submit an informal review request for CMS to investigate the payment adjustment. CMS will verify incentive eligibility and payment adjustment determinations for those who file a request.
Submit your informal review request electronically via the CMS QualityNet website. All requestors will be contacted by CMS with a final decision within 90 days of the original request. For additional questions regarding the informal review process, contact the QualityNet Help Desk at 1-866-288-8912 or Qnetsupport@hcqis.org. Submit your request between December 8 and December 16, as CMS has said its systems will be down on December 3 – 7.
For assistance and questions concerning PQRS reporting, please contact ACR staff at email@example.com.
From SGR repeal to a safe harbor period for the implementation of ICD-10, ACR/ARHP members have made a huge difference both on Capitol Hill and in local constituencies.
View a handy infographic showing everything our advocates have done in 2015.
Like me, I’m sure you are already experiencing donation fatigue between “Giving Tuesday,” “Holiday Appeals” and “End of the Year Requests” from many, many worthwhile organizations and causes. We all have a desire to help those who are needy as well as to try and decide how best to spend our money to do the most good. These are exceptionally worthy goals and priorities, and we should all aspire to contribute according to our abilities and preferences.
But before you consider donating to anyone else, follow the (paraphrased) advice of financial planners and “Pay yourself (your profession and patients) first” by donating to RheumPAC. If you donate before Dec. 15, 2015, 17 members of the ACR leadership will add a total of at least $51 to your donation of any amount.
That means a $25 donation is now $76, $100 becomes $151 and $1,500 becomes $1,551. (I love palindromes!) While more dollars per person is obviously desirable, I am more interested in greater participation by the ACR and ARHP membership, so please give what you can. And feel free to join our leadership’s challenge group to multiply everyone’s donations.
We are entering the period of the election cycle when politicians are especially eager for donations. Your contributions facilitate relationships and access for our members and staff to meet with our legislators—a.k.a. our “hired help.” As you may have learned at the Annual Meeting, there are many impending issues that will potentially impact each of us negatively. The ACR has influenced or defused many similar potential landmines in the past and we can do it again, but only with your help.
Your RheumPAC donations help make it easier for our members and staff to meet directly with the legislators who will decide our futures. In other words, your donations will directly help you, your profession and your patients.
Please donate now and encourage your associates, trainees and allied professionals who are ACR or ARHP members and U.S. citizens to do the same.
We have been able to accomplish amazing things with less than 4% of ACR members currently contributing to RheumPAC. Imagine how much more the ACR could do for you with your help. Pay yourself first.
Harry L. Gewanter, MD, FAAP, FACR