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MGMA's statement to the Senate Committee on Finance articulates the association’s priorities related to the MACRA statute and its two payment pathways: The Merit-based Incentive Payment System (MIPS) and alternative payment models (APMs). While supporting MACRA’s overall framework, MGMA makes a number of recommendations aimed at improving MACRA, including:

·     Simplify MIPS scoring and reduce reporting burdens;

·     Extend the availability of the APM incentive bonus; and

·     Continue to provide stable, positive updates to the Physician Fee Schedule for all services.

Congress introduced the Safe Step Act (H.R. 2279), which requires group health plans to adhere to common-sense parameters and reasonable timelines around the practice of step therapy. MGMA supports this bipartisan bill as it aims to improve step therapy protocols to ensure that patients have timely access to appropriate care while reducing physician practice burden associated with step therapy. Members are encouraged to contact their congressional representatives through MGMA’s “Contact Congress” portal and urge them to support the Safe Step Act.

MGMA joined a broad industry coalition including the American Academy of Family Physicians, American College of Cardiology, American College of Radiology, America’s Health Insurance Plans, UnitedHealthcare, and more than 20 other organizations to develop a set of four considerations focused on improving, reforming, and streamlining the prior authorization (PA) process. The considerations include: 

• Increasing transparency;  
• Reducing PA volume;
• Increasing use of existing electronic standards; and 
• Exploring bundled authorizations. 

The coalition is exploring pilot programs based on these considerations.

President Trump released his $4.7 trillion fiscal year (FY) 2020 budget request, which includes several Medicare proposals relevant to medical practices, such as expanding prior authorization. Presidential budgets do not have the force of law and are intended to serve as statements of administrative priorities, while Congress negotiates the budget. MGMA will continue to advocate on behalf of our members throughout the budget negotiation process. 

MGMA reminds members that the deadline for submission of 2018 performance year data for the Merit-based Incentive Payment System (MIPS) is April 2, 2019 at 8:00 p.m. ET. MIPS participants must submit data and receive a minimum of 15 points in order to avoid a negative payment adjustment in 2020.

MGMA encourages all members to log into their HCQIS Access Roles and Profile (HARP) accounts as soon as possible and make sure they are on track to complete all data submissions by this deadline. Reach out to MGMA’s Government Affairs team with any questions or concerns about submitting your MIPS performance data. 

In a letter to the Secretary of the Department of Health and Human Services (HHS), the National Committee on Vital and Health Statistics (NCVHS) recommended new approaches to improve the adoption of national healthcare standards. The NCVHS, a federal body named in HIPAA as an HHS advisor, issued a number of recommendations: (i) remove the regulatory mandate for modifications to adopted standards and move towards industry-driven upgrades; (ii) promote and facilitate voluntary testing and use of new standards or emerging versions of transactions or operating rules; (iii) improve the visibility and impact of the administrative simplification enforcement program; and (iv) provide policy-related guidance from HHS regarding administrative standards adoption and enforcement. MGMA testified before the NCVHS in December and the letter closely aligns with the Association’s recommendations. HHS is expected to act on the NCVHS recommendations later this year. 

In response to MGMA member concerns whether new Medicare Beneficiary Identifiers (MBIs) contain the number “0” or the letter “O” on new Medicare cards, CMS clarified that the MBI uses numbers 0-9 and all uppercase letters except for S, L, O, I, B, and Z. As a reminder, starting Jan. 1, 2020, Medicare will only accept the MBI on claims, and practices can access their MBIs via your Medicare Administrative Contractor web portal. Download the member-benefit New Medicare Card Toolkit for additional information on the transition to the new cards and numbers.  

The Office of the National Coordinator for Health Information Technology (ONC) released its proposed rule implementing provisions of the 21st Century Cures Act. Issues covered in the rulemaking include prohibitions against the blocking of data by providers or EHR vendors, the development and deployment of Application Programming Interface (API) standards, EHR developer certification, development of pediatric health information technology, practice ability to export patient data from one EHR to another, and other topics. Concurrently, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule on patient access to data using APIs, health information exchange across health plans, and other topics. Both agencies also included an RFI on the issue of accurately matching patient records. ONC and CMS will accept comments on these proposals until mid-April. MGMA will comment on each of these rules and the RFI.

MGMA joined over 100 medical societies and associations to voice concern to Congress regarding the impact unexpected medical bills have on patient out-of-pocket costs. In the letter, we argue that the issue is complex and requires a balanced approach to resolve. Included in the letter is a list of policies for Congress to consider, including insurer accountability, limits on patient responsibility, and promoting transparency. 

MGMA submitted comments in response to an Office for Civil Rights (OCR) Request for Information (RFI) on modifying HIPAA to facilitate care coordination and support value-based care. MGMA identified opportunities to reduce administrative burden, particularly with regards to patient acknowledgement of practice privacy policies. The Association pushed back on forcing practices to disclose patient records when requested by other providers or business associates, arguing clinicians should be permitted to use professional judgement to determine when a disclosure is appropriate. Also, MGMA strongly opposed the expansion of the current accounting of disclosures report to include disclosures made for purposes of treatment, payment, or healthcare operations. OCR is expected to publish regulations later this year.