- The document discusses updates from CMS on addressing administrative burden as part of the Quality Payment Program. Recent regulatory activities have aimed to reduce burden through changes to fee schedules, measure alignment, and telehealth coverage.
- CMS priorities include empowering patients, supporting state flexibility and local leadership, and improving the customer experience. The Innovation Center tests new payment and delivery models to improve quality and reduce costs.
- Under MACRA, clinicians can participate in the Merit-based Incentive Payment System or Advanced Alternative Payment Models. Technical assistance is available to help clinicians succeed under the Quality Payment Program.
Administrative Burden: Legislative and Regulatory Advocacy to Improve Physician Wellness - Wolfe
1. Quality Payment Program
CMS Update:
Addressing Administrative Burden
Ashby Wolfe, MD, MPP, MPH
Chief Medical Officer, Region IX
Centers for Medicare and Medicaid Services
Presentation to the American Academy of Family Physicians
State Legislative Conference
November 3, 2017
2. Quality Payment Program
This presentation was prepared as a tool to assist providers and is not intended
to grant rights or impose obligations. Although every reasonable effort has been
made to assure the accuracy of the information within these pages, the ultimate
responsibility for the correct submission of claims and response to any remittance
advice lies with the provider of services.
This publication is a general summary that explains certain aspects of the
Medicare Program, but is not a legal document. The official Medicare Program
provisions are contained in the relevant laws, regulations, and rulings. Medicare
policy changes frequently, and links to the source documents have been provided
within the document for your reference
The Centers for Medicare & Medicaid Services (CMS) employees, agents, and
staff make no representation, warranty, or guarantee that this compilation of
Medicare information is error-free and will bear no responsibility or liability for the
results or consequences of the use of this guide.
.
Disclaimer
3. Quality Payment Program
• Overview of CMS Priorities
• Recent Updates
- Regulatory activities to address administrative burden
• Fee Schedules and Prospective Payment System rules
- Measure alignment efforts
- Updates to the Innovation Center
- MACRA
• Regulatory Reform Initiative
Objectives for today
5. Quality Payment Program
Key CMS Priorities in health system transformation
1. Empower patients and clinicians to make decisions about
their health care.
2. Usher in a new era of state flexibility and local leadership.
3. Support innovative approaches to improve quality,
accessibility, and affordability.
4. Improve the CMS customer experience.
6. Quality Payment Program
• Provides greater potential for payment system modernization
• Sought public comment on reducing administrative burdens for providing
patient care, including visits, care management, and telehealth services.
• Takes steps to better align incentives and provide clinicians with a
smoother transition to the new Merit-based Incentive Payment System
under the Quality Payment Program (QPP).
• Makes additional proposals to implement the Center for Medicare and
Medicaid Innovation’s Medicare Diabetes Prevention Program expanded
model starting in 2018.
6
PROPOSED 2018 Medicare Physician Fee Schedule
Published July 13, 2017
For a fact sheet on the proposed rule, please visit:
https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-
sheets/2017-Fact-Sheet-items/2017-07-13-2.html
7. Quality Payment Program
• Medicare Telehealth Services - we are proposing to add several codes to the list of
telehealth services, including:
- HCPCS code G0296 (visit to determine low dose computed tomography eligibility);
- CPT code 90785 (Interactive Complexity);
- CPT codes 96160 and 96161 (Health Risk Assessment);
- HCPCS code G0506 (Care Planning for Chronic Care Management); and
- CPT codes 90839 and 90840 (Psychotherapy for Crisis)
• Improvement of Payment Rates for Office-based Behavioral Health Services
- CMS is proposing an improvement in the way rates are set that would increase
payment by better recognizing overhead expenses for office-based face-to-face visits
• Evaluation and Management Comment Solicitation
- CMS sought comment from stakeholders on specific changes we should undertake to
update the guidelines, to reduce the associated burden, and to better align E/M coding
and documentation with the current practice of medicine.
7
PROPOSED 2018 Medicare Physician Fee Schedule
Published July 13, 2017
https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2017-Fact-Sheet-items/2017-07-13-2.html
8. Quality Payment Program
• Changes to the Medicare and Medicaid EHR Incentive Programs
• For 2018, CMS is finalizing the modification to the EHR reporting periods for new and
returning participants attesting to CMS or their state Medicaid agency from the full year to a
minimum of any continuous 90-day period during the calendar year.
• Additional changes:
- Created a new exception from the Medicare payment adjustments for clinicians, eligible hospitals,
and CAHs that demonstrate through an application process that compliance is not possible
because their EHR technology has been decertified
- Finalized an exception to the 2017 and 2018 Medicare payment adjustments for ambulatory
surgical center (ASC)-based clinicians (those who furnish 75 percent or more of their covered
professional services in an ASC, using Place of Service (POS) code 24)
- Allow healthcare providers to use either 2014 Edition CEHRT, 2015 Edition CEHRT, or a combination
of 2014 Edition and 2015 Edition CEHRT, for the reporting period in 2018.
8
2018 Inpatient Prospective Payment System IPPS and
Long Term Care Hospital PPS Final Rule
Published August 2, 2017
For a fact sheet on the final rule, please visit:
https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2017-Fact-
Sheet-items/2017-08-02.html
9. Quality Payment Program
• Proposing to change the payment rate for certain Medicare Part B drugs purchased by
hospitals through the 340B program
- Requests comment on how CMS can best implement the proposal to pass savings on to
beneficiaries and providers, and to allow seniors to save money on their drug costs.
• The proposed rule also includes a provision that would alleviate some of the burdens rural
hospitals experience in recruiting physicians by placing a two-year moratorium on the direct
supervision requirement currently in place at rural hospitals and critical access hospitals.
• Request for Information on Flexibilities and Efficiencies
- Solicited feedback on positive solutions to better achieve transparency, flexibility, program
simplification and innovation.
- This will inform the discussion on future regulatory action related to outpatient services performed
at hospitals and services performed at ambulatory surgical centers.
9
PROPOSED 2018 Outpatient Prospective Payment System and
Ambulatory Surgical Center Payment System
Published July 13, 2017
For a fact sheet on the proposed rule, please visit:
https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2017-Fact-Sheet-
items/2017-07-13.html
10. Quality Payment Program
Measure Alignment Efforts
• CMS Draft Quality Measure Development Plan
- Highlight known measurement gaps and develop strategy to address these
- Promote harmonization and alignment across programs, care settings, and payers
- Assist in prioritizing development and refinement of measures
- Annual updates to the plan
• Core Measures Sets released in 2016, new PEDIATRIC measure set released 2017
- ACOs, Patient Centered Medical Homes (PCMH), and Primary Care
- Cardiology
- Gastroenterology
- HIV and Hepatitis C
- Medical Oncology
- Obstetrics and Gynecology
- Orthopedics
- Pediatrics
https://www.cms.gov/Medicare/Quality-Initiatives-
Patient-Assessment-Instruments/QualityMeasures/Core-
Measures.html
11. Quality Payment Program
The CMS Innovation Center was created by the
Affordable Care Act to develop, test, and implement
new payment and delivery models
“The purpose of the [Center] is to test
innovative payment and service delivery
models to reduce program
expenditures…while preserving or enhancing
the quality of care furnished to individuals
under such titles”
Section 3021 of
Affordable Care Act
Three scenarios for success
1. Quality improves; cost neutral
2. Quality neutral; cost reduced
3. Quality improves; cost reduced (best case)
If a model meets one of these three criteria
and other statutory prerequisites, the statute
allows the Secretary to expand the duration
and scope of a model through rulemaking
12. Quality Payment Program
Innovation Center Models
Variety of models and initiatives currently being tested across
several categories:
- Accountable Care
- Episode-based Payment Initiatives
- Primary Care Transformation
- Medicaid and CHIP Population focus
- Initiatives Focused on the Medicare-Medicaid Enrollees (“Dual-Eligibles”)
- Initiatives to Accelerate the Development and Testing of New Payment and
Service Delivery Models
- Initiatives to Speed the Adoption of Best Practices
13. Quality Payment Program
CMS has engaged the health care delivery system and
invested in innovation across the country
Models run at the state levelSites where innovation models are being tested
Source: CMS Innovation Center website, July 2017
17. Quality Payment Program
MACRA Goals
Through MACRA, HHS aims to:
• Offer multiple pathways with varying levels of risk and reward for
providers to tie more of their payments to value.
• Over time, expand the opportunities for a broad range of providers
to participate in APMs.
• Minimize additional reporting burdens for APM participants.
• Promote understanding of each physician’s or practitioner’s status
with respect to MIPS and/or APMs.
• Support multi-payer initiatives and the development of APMs in
Medicaid, Medicare Advantage, and other payer arrangements.
18. Quality Payment Program
The Quality Payment Program
The Quality Payment Program policy will:
• Reform Medicare Part B payments for more than 600,000 clinicians
• Improve care across the entire health care delivery system
Clinicians have two tracks to choose from:
5
19. Quality Payment Program
Test
• Submit some data after
January 1, 2017
• Neutral payment
adjustment
Partial Year
• Report for 90-day
period after January 1,
2017
• Neutral or positive
payment adjustment
19
Pick Your Pace for Participation for the Transition Year
Full Year
• Fully participate
starting January 1,
2017
• Positive payment
adjustment
MIPS
Not participating in the Quality Payment Program for the
Transition Year will result in a negative 4% payment adjustment.
Participate in an
Advanced Alternative
Payment Model
• Some practices may
choose to participate
in an Advanced
Alternative Payment
Model in 2017
Note: Clinicians do not need to tell
CMS which option they intend to
pursue.
21. Quality Payment Program
Technical Support Available to Clinicians
Integrated Technical Assistance Program
- Full-service, expert help
• Quality Payment Program Service Center
• Quality Innovation Network/Quality Improvement Organizations
• Quality Payment Program — Small, Underserved, and Rural Support
• Transforming Clinical Practice Initiative
• APM Learning Networks
- Self-service
• QPP Online Portal
21
All support is FREE to clinicians
https://qpp.cms.gov/education
22. Quality Payment Program
QPP Technical Assistance
• Technical Assistance organizations can help you:
- Understand the general requirements of the Quality Payment Program.
- Review the information included in your Clinician Participation Letter and/or help you use
the MIPS Participation Look-up Tool to determine if you are included in the program.
- Choose whether you will participate individually or as a part of a group.
- Pick a participation pace for the 2017 transition year.
- Identify appropriate MIPS measures and Improvement Activities based on your patients
and practice structure.
• Map your current efforts to appropriate MIPS measures and Improvement Activities.
- Determine a suitable submission mechanism(s) to report your data, create a strategy for
capturing data, and guide you through the submission process.
- Understand the MIPS scoring structure.
- Analyze your performance data and trends.
- Prepare to transition into an Alternative Payment Model (APM) or Advanced APMs.
22
What program-specific services are available?
23. Quality Payment Program
QPP Technical Assistance
• Technical Assistance organizations can help you:
- Assess your practice’s overall readiness for the Quality Payment Program.
- Implement change management and strategic planning.
- Redesign your practice workflow.
- Optimize your current Health Information Technology (HIT) or begin integrating
new forms of technology into your practice and select resources that meet
your patient’s needs.
- Form partnerships with other practices, local stakeholders, regional initiatives,
etc.
- Participate in a quality improvement initiative, if interested.
23
What practice-specific services are available?
27. Quality Payment Program
Thank you!
27
Ashby Wolfe, MD, MPP, MPH
Chief Medical Officer, Region IX
Centers for Medicare and Medicaid Services
ashby.wolfe1@cms.hhs.gov
Resources:
https://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-
Programs/Medicare-FFS-Compliance-Programs/ReducingProviderBurden.html
https://qpp.cms.gov/
https://www.cms.gov/Newsroom/MediaReleaseDatabase/Press-releases/2017-Press-
releases-items/2017-10-30.html