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Starting Jan. 1, Medicare will only accept the Medicare Beneficiary Identifier (MBI) on claims. CMS has indicated that 86% of Medicare claims currently contain the MBI. If patients do not present with their new Medicare card, you can access the MBI through your Medicare Administrative Contractor web portal. Download the member-benefit New Medicare Card Toolkit for additional information.

MGMA joined with 46 leading healthcare organizations urging the Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma to support efforts to more accurately match patient records. Currently, Congress prohibits CMS from working on establishing a national patient identifier. Physician practices and others often experience challenges ensuring that patients are correctly matched with their health records. Incorrectly matched records can lead to patient safety issues and additional administrative burdens. We request that Administrator Verma support lifting the prohibition on CMS providing technical assistance to private-sector led initiatives to more accurately identify patients and match them to their health information.

Practices interested in joining the Primary Care First (PCF), Direct Contracting, or Kidney Care Choices models should note the application periods are currently open. These models have various start dates, but financial accountability under all models will not begin until CY 2021, which is the first year each model will qualify as an Advanced alternative payment model (APM).

·     PCF: Applications are due by Jan. 22 for participation starting in 2021. 

·     Direct Contracting: A letter of intent to apply is due by Dec. 10 and applications are due by Feb. 25 for participation in the “Implementation Period” in 2020. The Implementation Period is intended to allow practices time to build relationships and develop infrastructure before assuming financial accountability in CY 2021. Alternatively, practices may forgo participation in an Implementation Period and begin participation in CY 2021; these practices do not need to submit an application at this time.

·     Kidney Care Choices: Like the Direct Contracting model, this model will have an Implementation Period in 2020, performance will begin in 2021, and only those seeking to participate in the Implementation Period need to submit an application by Jan. 22.

For more information, including links to application materials, visit MGMA’s APM landing page.

Group practices or individual eligible clinicians interested in applying for a hardship exception to the promoting interoperability category or an extreme and uncontrollable circumstances exception to other MIPS categories for the 2019 performance year must submit an application by Dec. 31. For more information, visit the Quality Payment Program resource library, which outlines eligibility, where to submit applications, and information on how approval will be noted.

MGMA submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the agency’s request for information on Medicare’s use of prior authorization. CMS is exploring the possibility of expanding the use of prior authorization for the Medicare program in an attempt to decrease cost. The Association highlighted the many administrative burdens physician practices face in meeting health plan prior authorization requirements and emphasized that these processes can delay or deny care to patients. MGMA recommended that Medicare limit any expansion of prior authorization, reduce the volume of prior authorization through exempting physicians who meet established clinical guidelines, and automate prior authorization in the limited situations when it is required.

A small group of leading healthcare organizations, including MGMA, American Medical Association, American Hospital Association, America’s Health Insurance Plans, and Blue Cross Blue Shield Association were invited to meet with top officials of the Centers for Medicare & Medicaid Services (CMS), including Administrator Seema Verma, to discuss prior authorization challenges. With MGMA members ranking prior authorization as their leading administrative burden, Anders Gilberg, Senior Vice President of MGMA Government Affairs, took the opportunity to advocate for reducing the overall volume of authorization requirements through gold carding and eliminating authorizations for routine services with high health plan approval rates. He also emphasized to CMS the need to standardize health plan medical necessity requirements, called for transparency of health plan approval rates by service and provider, and encouraged automation of prior authorization processes by leveraging national standards for electronic transactions and electronic clinical documentation attachments.

Medicare Open Enrollment ends on Dec. 7 and your Medicare patients may have questions about their benefits. The Department of Health and Human Services' Administration for Community Living has a resource for beneficiaries called the State Health Insurance Assistance Program. This free, federally-sponsored program serves to help beneficiaries understand their Medicare benefits and enrollment options.

Members whose clinicians or practices submitted data for the MIPS Total Per Capita Costs for All Attributed Beneficiaries (TPCC) measure or the MIPS Medicare Spending per Beneficiary (MSPB) cost measure in 2018 can utilize a new resource from CMS.

MGMA submitted comments to the Substance Abuse and Mental Health Services Administration (SAMHSA) in response to the agency’s proposal to modify the privacy requirements for sharing substance use disorder (SUD) information. SAMHSA proposed a number of modifications to current regulations that could impact medical group practices. Patients would be required to designate a practice, as opposed to a specific individual as currently required, to receive their SUD information, which MGMA supports. While MGMA expressed support for practice access to SUD information in emergency situations and to all state Prescription Drug Monitoring Program (PDMP) information, we expressed concern that certain non-clinicians, including law enforcement officials, could be given access to SUD and other sensitive patient data via the PDMP. 

Last week, the Centers for Medicare & Medicaid Services (CMS) opened the application period for the Primary Care First (PCF) advanced alternative payment model (APM) and also delayed the start date until Jan. 1, 2021. Practices applying to begin participation in 2021 will need to submit the application by Jan. 22, 2020. MGMA updated its member-resource outlining the PCF model to reflect these new details.

CMS also opened the application period for the Kidney Care Choices model, which will close on Jan. 22, 2020. Applications for the Kidney Care First model have not yet been released. Stay tuned to the Washington Connection for further announcements.