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MGMA joined the American Medical Association and more than 100 physician specialty and state medical organizations in a letter urging Congress to ensure smooth implementation of Medicare payment policies under the Medicare Access and CHIP Reauthorization Act (MACRA). In particular, MGMA and the medical community call for a three-year extension of program flexibility to ensure physician practices are able to successfully participate in the new Merit-Based Incentive Payment System (MIPS) while CMS finalizes cost measures, improves data feedback, and provides tools to improve performance. Among other refinements, the letter requested clarification that Medicare Part B drugs are outside the scope of MIPS payment adjustments.

MGMA offered recommendations to reduce unnecessary government regulations at the U.S. Department of Health and Human Services (HHS) “Cut the Red Tape” Summit this week. During their opening remarks, HHS Acting Secretary, Dr. Don Wright, CMS Administrator, Seema Verma, and other HHS officials reiterated the Department’s commitment to reducing excessive regulatory burdens on medical group practices. During the panel discussion, Anders Gilberg, MGMA’s Senior Vice President of Government Affairs, shared results from MGMA’s 2017 Regulatory Burdens survey that highlighted the considerable time and resources required to comply with federal mandates and identified key areas of concern for medical group practices, such as the lack of clinical relevance in Medicare’s Quality Payment Program. MGMA will continue to call on HHS to support innovative, high-quality, and cost-effective care delivery untethered from excessive, one-size-fits-all regulations. 

The Centers for Medicare & Medicaid Services (CMS) withdrew its proposal to change the way Medicare pays for drugs administered in physician offices. MGMA raised significant concerns regarding the proposed payment model, which would have reduced Medicare reimbursement without addressing the root cause of drug price increases set by the manufacturer. The Association also took issue with the fact that this mandatory model would establish a precedent under which the CMS Innovation Center could expand its limited legislative authority to circumvent the usual channels for changing physician payment. MGMA continues to recommend the agency seek physician practice input in developing payment models to support innovative approaches to improve quality and affordability without restricting patient access to life-saving treatments.

Group practices and eligible clinicians (ECs) seeking to earn a bonus in the Merit-Based Incentive Payment System (MIPS) in 2019 have until Oct. 2 to begin reporting one or more quality measures, improvement activities, or Advancing Care Information measures for the minimum 90 consecutive days. Conversely, group practices and ECs have through the end of the calendar year to avoid a 4% MIPS penalty in 2019 by reporting at least one quality measure on one patient. MGMA encourages practice executives to protect their practice from a Medicare payment cut by reporting more than one measure as an insurance policy in case the group encounters any data submission issues or inaccuracies. For resources to help your practice successfully participate in MIPS, visit MGMA.org/MACRA.

The latest Affordable Care Act (ACA) replacement proposal will not be brought to a vote in the Senate, after Susan Collins, R-ME, became the third Republican to publicly come out against it. MGMA expressed concerns over this latest proposed Senate bill based on our healthcare reform principles. The Senate appears willing to resume its own bipartisan efforts to stabilize the exchanges for next year.

CMS announced last month it will launch a new audit strategy, called Targeted Probe and Educate (TPE), after pilot programs with four Medicare Administrative Contractors (MACs) demonstrated success. Under the TPE approach, MACs will perform reviews on claims that pose the greatest financial risk to the Medicare trust fund or have a high national error rate. Unlike the previous policy where reviews were initiated on all providers of a particular service, MACs are now instructed to focus only on those providers, identified through data analysis, who have the highest claims error rates or billing practices that vary significantly from their peers. The TPE program includes up to three rounds of review, coupled with individualized education based on review results, and is expected to be expanded to all MAC jurisdictions - later this year.

Department of Health and Human Services (HHS) Secretary Tom Price, MD issued responses to the first physician focused payment models (PFPMs) reviewed by the PFPM Technical Advisory Committee (PTAC) in April. The Secretary asked that design concerns be addressed before making a final decision on the American College of Surgeons-Brandeis Model. HHS also indicated it would not be moving forward with the COPD and Asthma Monitoring Project and Project Sonar models, but would consider elements of those proposals when developing its own future models. Despite not proceeding with any of the proposals at this time, Price provided valuable insights to guide development of future PFPMs. He explained models that are broad in scope and feature enhanced patient monitoring to reduce complications and hospital admissions hold promise but that HHS is not interested in models that would not be implemented beyond the submitter or use proprietary technology.

A Sept. 5 MGMA Stat poll found that about 1 out of 6 practices report that their health plans charge transaction fees, typically ranging from 2-5%, to receive payments for medical services via Electronic Funds Transfer (EFT). As part of an effort in the Affordable Care Act to decrease healthcare administrative inefficiencies, CMS mandated a standardized EFT transaction and since 2014 health plans are required to offer EFT should providers request it. Contrary to the intent of the law, and despite the fact that health plans themselves save on printing and mailing costs, many practices are required to pay these EFT tolls. MGMA continues to strongly advocate that CMS issue guidance preventing health plans and payment vendors from charging these fees. Review the MGMA member-benefit EFT and ERA Guide.

MGMA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed 2018 Medicare physician fee schedule. The proposed rule includes a number of policies that, if finalized, would affect medical group practices in 2018. 

Among its recommendations, MGMA advocates for CMS to: 

• Finalize the proposed delay in requiring appropriate use criteria consultation and documentation; 
  
• Hold medical groups harmless from 2018 penalties in the obsolete PQRS, Meaningful Use, and Value Modifier programs if they reported some data in 2016; and
  
• Reduce unnecessary regulations and improve the quality and efficiency of healthcare delivery using the results of MGMA’s 2017 Regulatory Burdens survey as a compass. 

Gain insight about the impact of Medicare payment policies on your practice at MGMA17 in Anaheim. MGMA government affairs presentations will highlight legislative and regulatory issues critical to your group’s success, feature exclusive office hours with CMS’ Director of the Center for Clinical Standards and Quality, Dr. Kate Goodrich, and culminate in the popular “View from Washington” general session with MGMA’s Senior Vice President of Government Affairs. Register today to secure your spot.

MGMA joined several provider organizations in a letter urging the Centers for Medicare & Medicaid Services (CMS) to include group practices in value-based arrangements with Medicare Advantage (MA) plans in the Advanced alternative payment model (APM) track of MACRA. Last week, CMS announced nearly 100% of participants in designated Advanced APMs are expected to qualify for a 5% bonus and exemption from the Merit-Based Incentive Payment System (MIPS) based on historical claims data. However, even if 100% of current Advanced APM participants qualify, this is estimated to amount to just 10% of all eligible clinicians in 2017 due to the limited number of existing Advanced APMs. MGMA has repeatedly called for expanded opportunities for group practices to move away from MIPS into the APM track, and we believe adding qualifying MA risk-based arrangements to the Advanced APM list is an important step in this direction.