Archive for October, 2016

What You Said About MACRA…

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What You Said About MACRA…

Just a few weeks ago, the Department of Health & Human Services dropped the finalized Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) rule – a landmark new payment system moving health care to a merit-based payment system. The rule, weighing in at almost 2,400 pages, has garnered more than 4,000 public comments since its proposal in April, is scheduled to become effective Jan. 1, 2017. With so little time to prepare, we asked some of Alabama’s physicians what they think about MACRA.

 

“MACRA is a very complex law and will be a burden for many of our physicians. However, please remember that MACRA repealed and replaced the SGR, the flawed program where we all annually faced pay cuts of 20 percent and greater and were always at the mercy of Congress to provide relief that almost always came at the last minute. With MACRA, we have the stability of knowing what to expect, we have the potential of increased payments and even bonus payments along with the possibility of negative updates as well. If you participate in Pick-Your-Pace at any level of participation in 2017, you will avoid any potential penalties in 2019, the first year of MACRA implementation. The MACRA updates in 2019 start at +/- as much as 4 percent and go up slowly each year but come nowhere close to the 21 percent cuts we faced under SGR. MACRA is by no means perfect, but it does begin the Medicare transition from volume-based Fee-For-Service payments to a value-based payment system. I would encourage all physicians to participate in Pick Your Pace at whatever level you are able to accomplish in 2017 to avoid potential penalties in 2019. As we delve deeper into this law, stay tuned for future updates and recommendations.” – John Meigs Jr., M.D., Brent

“Because I see very little Medicare patients, I have not studied MACRA or MIPS other than to know it will be a burden to physicians and staff in time or expense to hire a third party to do the reporting requirements. For physicians like me that see little Medicare patients, but just enough (about 100 a year) to be required to do the reporting to be penalized, it is burdensome. I may take the penalty and then ultimately not see Medicare anymore because it isn’t cost efficient for my practice. The government is continually putting more costly regulations and requirements on physician practices pressuring the overall viability of a private practicing physician in the future. There will come a breaking point.” – McCain Ashurst, M.D., Montgomery

“They’re talking about a reduction in payments for failing to meet standards, but how do you assess that — what metric do you use? How do you assess quality? And there’s a lot of flippant interpretations of what they’ll pay.” – Clifford Black, M.D., Anniston, quoted in The Anniston Star

“We’ll just have to pay more attention to what we do … how often patients get treatment … show that patients are getting proper quality of care … if you do it enough it’ll eventually become second nature. But it is a slightly greater bureaucratic level on physicians. Generally, the quality of care is good right now … maybe there will be a 1 to 2 percent improvement.” – Todd Scarbrough, M.D., Anniston, quoted in The Anniston Star

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Stay Safe on Halloween!

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Stay Safe on Halloween!

Walk Safely

  • Cross the street at corners, using traffic signals and crosswalks.
  • Look left, right and left again when crossing and keep looking as you cross.
  • Put electronic devices down and keep heads up and walk, don’t run, across the street.
  • Teach children to make eye contact with drivers before crossing in front of them.
  • Always walk on sidewalks or paths. If there are no sidewalks, walk facing traffic as far to the left as possible. Children should walk on direct routes with the fewest street crossings.
  • Watch for cars that are turning or backing up. Teach children to never dart out into the street or cross between parked cars.

Trick or Treat with an Adult

  • Children under the age of 12 should not be alone at night without adult supervision.
  • If kids are mature enough to be out without supervision, they should stick to familiar areas that are well lit and trick-or-treat in groups.

Keep Costumes Creative and Safe

  • Decorate costumes and bags with reflective tape or stickers and, if possible, choose light colors.
  • Choose face paint and makeup whenever possible instead of masks, which can obstruct a child’s vision.
  • Have kids carry glow sticks or flashlights to help them see and be seen by drivers.
  • When selecting a costume, make sure it is the right size to prevent trips and falls.

Drive Safely

  • Slow down and be especially alert in residential neighborhoods. Children are excited on Halloween and may move in unpredictable ways.
  • Take extra time to look for kids at intersections, on medians and on curbs.
  • Enter and exit driveways and alleys slowly and carefully.
  • Eliminate any distractions inside your car so you can concentrate on the road and your surroundings.
  • Drive slowly, anticipate heavy pedestrian traffic and turn your headlights on earlier in the day to spot children from greater distances.
  • Popular trick-or-treating hours are 5:30 p.m. to 8:30 p.m. so be especially alert for kids during those hours.

Carefully Screen ALL Candy and Goodies

  • Make sure wrappers are secure for all your candy and goodies. If you have any suspicions, you can take your candy to your local police department or hospital to be scanned for any metal pieces. Always trick or treat at the homes of people that you know.

Finally, if the lights are off, no trick or treating! Have a safe and happy Halloween!

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The Importance of Accurate Timekeeping

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The Importance of Accurate Timekeeping

Accurate and up-to-date record keeping is one of the most crucial elements of a successful business – no matter what size. Chief among these types of record keeping is timekeeping – keeping track of the hours the members of your team bills to the company, as well as time off for vacations and sick leave.

Why is accurate timekeeping so critical? Here’s a look at some of the problems that can arise if it isn’t accurate:

  • Wasted time. If you don’t have a precise record of how much time your workforce is really investing, then there’s no way to judge your return on investment and resulting company profitability. You also prevent yourself from being able to identify processes that are inefficient (for example, accurate timekeeping can help you determine if there’s a particular task that takes your employees a long time to complete on a regular basis, and therefore could benefit from automation, additional training, and so on).
  • Wasted money. Small business owners especially need to spend their money wisely. Even if your timekeeping records are only off by a small amount, the resulting loss in profitability can really mount over time – and you may end up spending even more money trying to correct mistakes.
  • Tax compliance issues. As we’ve discussed before, tax compliance is not a nice-to-have. It’s a necessity. Accurate timekeeping ensures accurate tax filing for each of your employees.
  • Employee (and employer) quality of life. Your employees want to be compensated appropriately for the time they spend on the job. And you want to make sure that you’re protected against time theft, human errors, and other potentially big problems. By ensuring that both issues are being addressed efficiently and professionally, you make everyone’s work-life a lot more enjoyable.

*Editor’s Note: Apex Payroll is a partner with the Medical Association. To receive up to 20% off your payroll fees, and to discover other Apex Payroll services, click here.

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Death vs. Another Hospital Stay: Study Suggests Medicare Should Weigh Them Equally

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Death vs. Another Hospital Stay: Study Suggests Medicare Should Weigh Them Equally

ANN ARBOR — In the last few years, American hospitals have focused like hawks on how to keep patients from coming back within a few weeks of getting out.

Driven by new Medicare penalties for such events, the effort has slowed a ‘revolving door’ of readmissions for heart attack, heart failure and pneumonia patients that costs the nation billions of dollars.

But, a new analysis suggests that Medicare should focus more on how well hospitals do at actually keeping such patients alive during the same time.

If hospitals got paid less when their patients died soon after a hospitalization, just like they get paid less when those patients end up back in the hospital, it would be a game-changer for one-third of hospitals, say researchers from the University of Michigan Medical School and VA Ann Arbor Healthcare System who published their findings in JAMA Cardiology.

According to the study, about 17 percent of hospitals are getting punished for excess readmissions, but are keeping patients alive more often than would be expected, and another 16 percent of hospitals essentially get rewarded for low readmission rates, but their patients are more likely to die in the first month after leaving their hospital beds.

In other words, some of the hospitals that get penalized for high readmissions are those that may actually do the best job at keeping patients alive – and vice versa.

Preventive incentives

If the penalties took both readmission and mortality into account, the Medicare system would save the same amount of money, but incentivize good outcomes more fairly, the researchers said.

“Under most circumstances, hospital patients would much rather avoid death than readmission,” said Scott Hummel, M.D., M.S., senior author of the new paper and a heart failure cardiologist. “But the incentive to prevent death in the first 30 days after a hospitalization is 10 times less than the incentive to prevent a return hospital visit.”

He and his colleagues hope their analysis will spark a conversation about how to fine-tune the Medicare system’s effort to encourage better performance by America’s hospitals.

Their work is based on data from 2014, the first year when hospitals could both be penalized for readmission rates that were higher than expected and earn a financial reward based on a mix of measures that include everything from 30-day death rates to how well patients rated the care they received and the hospital environment.

Under the current policy, hospitals can lose up to three percent of condition-related payments from Medicare for excess readmissions but can recoup only about 0.2 percent of such payments for having low mortality rates.

First author Ahmad Abdul-Aziz, M.D., an internal medicine resident at U-M, helped coordinate the data analysis using publicly available data from the Centers for Medicare and Medicaid Services, called CMS for short. Some of it was accessed via an online system created by Kaiser Health News, based on data from CMS. In all, data from 1,963 hospitals was included.

The authors, who also include senior team members Rodney Hayward, M.D., and Keith Aaronson, M.D., M.S., calculated a ratio for each hospital based on observed and expected readmissions and mortality in the first 30 days for heart attack, heart failure and pneumonia. Although other conditions were added to the readmission program in 2015 and 2016, they weren’t included because these diagnoses are not yet included in the reward program for low mortality rates.

All the data were adjusted for how sick each hospital’s patients were when they started, using standard methods that allow an apples-to-apples comparison. The socioeconomic status of each hospital’s patients, which can also affect patient outcomes but aren’t in a hospital’s control, wasn’t included because CMS hadn’t yet started taking it into account in 2014.

The authors don’t take issue with the idea of penalizing excess readmissions — though they do note that readmissions for any cause are included in the program, not just readmissions for the problem that sent the person to the hospital in the first place.

Admissions to any hospital within 30 days of discharge count against the hospital that the patient was discharged from, which may work against large hospitals that patients travel to for advanced care before returning to their home area.

Other researchers have shown there isn’t a tight link between a hospital’s 30-day readmission rate and the 30-day mortality rate for its patients with these conditions — suggesting that there’s more to the story when thinking about using them as measures of hospital quality.

The authors also call for continued improvement in risk models that will more precisely predict a patient’s risk of readmission, just like current, well-tested models to predict their risk of death.

Better tools would mean better ability to test a hospital’s actual performance against what might be expected based on their entire patient population. The researchers also plan to examine what kinds of hospitals are most likely to win or lose financially if the balance shifts between penalties for reducing readmissions and those for reducing early mortality.

“The misaligned incentives for preventing readmission and preventing death may help explain why some hospitals are doing really well on one, but not on the other,” said Hummel. “It’s important we continue to reduce preventable readmissions, but we need to watch out for unintended consequences too.

“Sometimes, a readmission might be a good thing — no one wants to see patients die because they should have been readmitted,” he added. “If financial penalties drive hospitals to figure out how to improve outcomes, increasing incentives to reduce early post-hospital deaths seems like a good place to start.”

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Deadline for Seeking Review of Potential Payment Penalties

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Deadline for Seeking Review of Potential Payment Penalties

Late last month, the Centers for Medicare and Medicaid Services posted information on its website that physicians can consult to determine whether they will be subject to 2017 payment penalties associated with the Physician Quality Reporting System (PQRS) and the Value Modifier. Physician practices that have concerns about the findings in their report(s) have until November 30 to file for an informal review of their data.

These penalties stem from policies in effect prior to the enactment of the Medicare Access and CHIP Reauthorization Act. Failure to successfully complete required PQRS reporting will result in a 2 percent penalty. Value Modifier penalties can range from 1 percent to 4 percent depending on the size of the practice and its performance on cost and quality measures. PQRS penalties will be communicated to physicians by mail as well as in the PQRS feedback reports posted on the CMS website. Value Modifier penalties and bonuses can be found in Quality and Resource Use Reports (QRURs) posted on the website only.

Additional information on accessing the reports and filing for an informal review can be found in the attached documents. Those who have questions, even if they are uncertain about penalty status, are urged to submit a request for informal review. Although in most cases a successful PQRS review will trigger an automatic review of related VM penalties, program officials say the safest course is to file requests for review of both PQRS and VM data.

Follow these steps to submit an informal review request:

  1. Go to the Quality Reporting Communication Support Page (CSP)
  2. In the upper left-hand corner of the page, under “Related Links,” select “Communication Support Page”
  3. Select “Informal Review Request”
  4. Select “PQRS Informal Review”
  5. A new page will open
  6. Enter Billing/Primary Taxpayer Identification Number (TIN), Individual Rendering National Provider Identifier (NPI), OR Practice Site ID # and select “submit”
  7. Complete the mandatory fields in the online form, including the appropriate justification for the request to be deemed valid. Failure to complete the form in full will result in the inability to have the informal review request analyzed. CMS or the QualityNet Help Desk may contact the requestor for additional information if necessary.

Please see “2015 PQRS: 2017 PQRS Negative Payment Adjustment — Informal Review Made Simple” available on the PQRS Analysis and Payment webpage for more information.

NOTE: The CSP will be unavailable November 18-20 for maintenance.

Additionally, 2015 PQRS feedback reports can be accessed on the CMS Enterprise Portal using an Enterprise Identity Management (EIDM) account. For details on how to obtain your report, please see the “Quick Reference Guide for Accessing 2015 PQRS Feedback Reports.” For information on understanding your report, please see the “2015 PQRS Feedback Report User Guide.” Both guides are on the PQRS Analysis and Payment webpage.

For additional questions regarding the informal review process, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or Qnetsupport@hcqis.org Monday-Friday from 7:00 a.m. to 7:00 p.m. CT. To avoid security violations, do not include personal identifying information, such as Social Security Number or TIN, in e-mail inquiries to the QualityNet Help Desk.

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Injured? Dial 1-800-4-MED-MAL

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Injured? Dial 1-800-4-MED-MAL

Legislation Threatens Decades of Medical Tort Reforms

If 1-800-4-MED-MAL sounds like a personal injury firm advertisement, think again. But if proponents of a radical new alternative medical liability system get their way, 1-800-4-MED-MAL could be an avenue for turning every persistent migraine, bout of acute pain and post-operative bruise into cash payments.

This radicalized approach – called the Patients’ Compensation System (PCS) – would abolish a physicians’ right to trial by jury and undo decades of tort reforms championed by the Medical Association, laws that foster a stable liability environment in Alabama and laws which must be defended from personal injury lawyer attacks each year. Proponents of the PCS want Alabama physicians to trade existing, proven protections from trial lawyer shenanigans for the false hope of an untested, unrealistic and radical approach to medical liability.

Let’s examine arguments by proponents of PCS legislation one by one.

Proponents Say PCS Will Be Good for Physicians

While supporters claim the PCS would free physicians from burdens of the civil justice system, the opposite is true. The Medical Association won numerous hard-fought battles with personal injury lawyers since the 1980s in order to bring stability to Alabama’s medical liability environment. Maintaining that stability can only be achieved through a vigilant defense at the Legislature.

If it became law, the PCS would levy an annual tax on physicians to fund a new state government agency to handle all claims of physical injury or death allegedly at the hands of M.D.s and D.O.s. The PCS would be mandatory, with no option for a jury trial. The PCS would have authority to investigate, determine fault and award damages. Instead of a plaintiff hiring an attorney to file suit, each claim under the PCS would be initiated by dialing a 24-hour hotline.

The PCS would not govern allegations filed against a hospital though, meaning a physician could still be party to a suit involving an institution even with the PCS in place. Unlike a professional liability policy, the costs for defense counsel would not be included in the annual payment to the PCS. The committees reviewing PCS claims would be largely political appointees, meaning a physician’s fate could hinge on who’s in office at the time a claim is made. If the PCS found wrongdoing by a physician and compensated a claimant, it would be reported to the National Practitioner Databank. With the bar for entry lowered to the level of a phone call, a “woodwork effect” as word spreads about the PCS is an almost certainty. With the subsequent spike in payouts, Alabama physicians could see reports for minor injuries to the National Practitioner Databank increase as exponentially as their taxes to fund the PCS.

Proponents Claim PCS Will Be Good for Patients

Those pushing the PCS say the current system doesn’t adequately compensate injured patients, and those compensated wait too long for justice. Few physicians who’ve been sued would argue the civil justice process is a short one, but that is indicative of long dockets that are the product of an overly-litigious culture.

The practice of medicine is just that; a practice, with few certainties. Most patient injuries are no one’s specific fault. In a minority of situations, the opposite is true and those injured should be able to seek recourse. But under the bureaucrat-run PCS, the number of claims paid for even minor injuries could increase sharply, quickly depleting the balance of available funds through thousands of small payouts, funds that should be reserved for the aforementioned minority of situations of serious physical injuries or death.

Once the funds from the PCS physician tax dries up each year, no further claims can be paid, even those already filed but not completed. Given that, instances of serious physical injury would fare better in the court system. The PCS proponents also promise a dramatic reduction in the length of time between injury and award. That’s difficult to believe as few if any government programs have actually improved efficiency for those utilizing them.

Proponents Say PCS Will Reduce “Defensive Medicine”

Promised as a way to reduce unnecessary care and thereby shrink Medicaid expenses by giving physicians liability comfort, PCS supporters cling to the flawed premise physicians base their medical decisions on criteria other than established standards and what’s best for the patient. Statements to the contrary are not only insulting to most physicians, they’re false, as anyone intentionally billing unnecessary services would be committing fraud. Whether under the civil justice system or the PCS, standards of care will still exist. And, because all awards for injury are reported to the National Practitioner Databank, the reporting of thousands of minor injury awards under the PCS might actually encourage additional testing and procedures, creating the opposite atmosphere PCS proponents claim their system will eliminate.

Proponents Say PCS Will Cut Health Care Costs, Especially in Medicaid

Also proposed as a cost savings for Alabama Medicaid via anticipated reduction of alleged unnecessary care, PCS supporters claim Alabama physicians order more than $1 billion worth of “defensive medicine” for fear of being sued. They claim the PCS, if implemented, could substantially slash the cost to Medicaid alone by hundreds of millions of dollars. As explained above, the myth of “defensive medicine” doesn’t hold up. How could a radical new system that pays out substantially more claims for injuries contain even its own expenditures, much less curb the growth in health care costs? The PCS will create a “woodwork effect” expected to increase the cost each year, leaving physicians burdened with higher taxes to fund the unrestrained and irresponsible growth.Conclusion

Conclusion

The PCS is an expansion of big government-funded on physicians’ backs that will undo decades of significant tort reforms. With uncertainty already surrounding the future of the state’s Medicaid program, destroying Alabama’s medical liability environment could push physicians into early retirement or send them to states with more stable liability atmospheres. The PCS legislation and its empty promises should be cast aside in favor of meaningful civil justice reforms that solve problems instead of creating them. The PCS is indeed an answer in search of a question, and one that’s bad for patients, bad for physicians and wrong for Alabama.

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Danger Exists from Use of Synthetic Cannabinoids

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Danger Exists from Use of Synthetic Cannabinoids

The Alabama Department of Public Health and the Medical Association cautions the public about the hazards associated with the use and the risk to the public from synthetic cannabinoids also known as synthetic marijuana.

Users of the synthetic mixtures typically experience symptoms that include rapid heart rate, nausea and vomiting, agitation, confusion, sleepiness, hallucinations, kidney and respiratory problems.

The designer drug substances consist of dried plant material sprayed with synthetic cannabinoids and any mixture of other unknown chemicals including pesticides and rat poison. The chemical compounds reportedly stimulate the same brain areas affected by marijuana, and they have a high potential for abuse. These synthetic drugs are very dangerous and can be deadly said Dr. Karen Landers, pediatrician and Assistant State Health Officer.

“Responses to these chemicals can be unpredictable. People have experienced coma, kidney failure, and heart attacks just to mention some of the effects experienced by users. Please do not take the risk by using these products,” Dr. Landers stated.

Hundreds of different variants are marketed under names that include “Spice,” “K2,” “Spice Gold,” “Sence,” “Genie,” “Zohai,” “Yucatan Fire,” “Smoke,” “Sexy Monkey,” “Black Mamba” and “Skunk.”

The possession or sale of chemical compounds typically found in these synthetic substances is unlawful.

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New CDC Study: Changes in Breast Cancer Death Rates by Age Group

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New CDC Study: Changes in Breast Cancer Death Rates by Age Group

Breast cancer death rates among women decreased during 2010-2014, but racial differences persisted, according to a new study by the Centers for Disease Control and Prevention. The findings show changes for death rates from breast cancer by age group for black and white women, the groups with the highest death rates in the United States.

“Our latest data suggest some improvement for black women when it comes to disparities,” said Lisa Richardson, MD, Director of CDC’s Division of Cancer Prevention and Control. “First, the decline in deaths suggests that white and black women under 50 are benefiting equally from cancer treatments. Second, we’re hopeful the lack of difference in death rates between black and white women under 50 will start to be seen in older women.”

Data Highlights

  • There was a faster decrease in breast cancer death rates for white women (1.9% per year) than black women (1.5 percent per year) between 2010 and 2014.
  • Among women under age 50, breast cancer death rates decreased at the same pace for black and white women.
  • The largest difference by race was among women ages 60-69 years: breast cancer death rates dropped 2.0 percent per year among white women, compared with 1.0 percent per year among black women.

The authors noted that the drop in death rates among women may be due to improved education about the importance of appropriate breast cancer screening and treatment, as well as women having access to personalized and cutting-edge treatment.

“The good news is that overall rates of breast cancer are decreasing among black women. However, when compared with white women, the likelihood that a black woman will die after a breast cancer diagnosis is still considerably higher,” said Jacqueline Miller, M.D., and medical director of CDC’s National Breast and Cervical Cancer Early Detection Program.

What Can be Done to Reduce Breast Cancer Risk

Personalized medical treatments combined with community-based cancer control efforts that ensure adequate follow-up and treatment after a cancer diagnosis could help decrease breast cancer death rates faster and reduce differences among black and white women.

Women can take steps to help reduce their breast cancer risk by knowing their family history of cancer, being physically active, eating a healthy diet, maintaining a healthy weight, and getting recommended cancer screenings.

CDC’s National Breast and Cervical Cancer Early Detection Program provides access to timely breast and cervical cancer screening and diagnostic services for low-income, uninsured, and underserved women. It is the largest organized cancer screening program in the U.S. and offers free or low-cost mammograms to women who qualify.

CDC’s Bring Your Brave campaign provides information about breast cancer to women younger than age 45 by sharing real stories about young women whose lives have been affected by breast cancer.

The United States Cancer Statistics web-based report contains the official federal statistics on newly diagnosed cancer cases. CDC and the National Cancer Institute have combined their cancer incidence data sources to produce these statistics. Mortality data are from CDC’s National Vital Statistics System. CDC provides support for states and territories to maintain registries that provide high-quality data through the National Program of Cancer Registries.

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Health Care Personnel Need Flu Shots, Too

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Health Care Personnel Need Flu Shots, Too

The Alabama Department of Public Health, the Medical Association of the State of Alabama and the Alabama Hospital Association have issued a joint statement emphasizing the importance of health care personnel receiving influenza vaccinations, urging this simple but significant infection prevention measure to protect patients.

Influenza is a serious illness that can lead to hospitalization and sometimes death. It is especially dangerous for those at high risk, including the very young, the elderly, and those with other chronic health conditions and compromised immune systems.

It has been documented that health care workers can receive and transmit the flu virus to and from their patients and that annual vaccination of health care personnel is important in preventing the spread of the virus and thus ensuring a safe environment for patients.

Many of these hospitalizations and deaths can be prevented by the widespread use of influenza vaccine, essentially “cocooning” patients from potential flu transmission by health care workers. The CDC estimates that 200,000 Americans are hospitalized each year with the flu and that deaths due to flu have ranged from 3,000 to 49,000 deaths annually.

All health care personnel should receive the flu vaccination annually as soon as vaccine is available. This includes full and part-time employees, staff and licensed independent practitioners, and individuals involved in direct patient care.

For more information, contact Karen Landers, M.D., F.A.A.P., (256) 246-1714 (Alabama Department of Public Health); Rosemary Blackmon, 800-489-2542 (Alabama Hospital Association); or Lori M. Quiller, APR, (334) 954-2580 (Medical Association of the State of Alabama)

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CMS Releases MACRA Final Rule

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CMS Releases MACRA Final Rule

*Editor’s Note: The Medical Association will be studying the just-released MACRA rule and will be providing additional info as it becomes available. The Association and MGMA will co-host a free webinar, “MACRA: Essential Strategies in Economic Reform” on Nov. 7 from 12 p.m. to 1:30 p.m. Click here for more information.

On Oct. 14, the Department of Health & Human Services finalized a landmark new payment system for Medicare physicians that will continue reforming how the health care system pays for care. The rule, which since its proposal in April garnered more than 4,000 public comments, cements the two payment tracks already proposed and is scheduled to become effective Jan. 1, 2017.

First, physicians can participate in the Merit-Based Incentive Payment System track, which based payment of clinic performance, practice improvement, reporting and technology use. However, the final rule makes official the “pick-your-pace provision” allowing physicians a slower entry into the model if they are not quite prepared to handle all aspects of the program. To do that, CMS is offering physicians a flexible performance period at the beginning.

“It’s time to modernize the Medicare physician payment system to be more streamlined and effective at supporting high-quality patient care. To be successful, we must put patients and clinicians at the center of the Quality Payment Program,” said Andy Slavitt, Acting Administrator of the Centers for Medicare & Medicaid Services (CMS). “A critical feature of the program will be implementing these changes at a pace and with options that clinicians choose. Today’s policies are designed to get all eligible clinicians to participate in the program, so they are set up for successful care delivery as the program matures.”

The rule, which weighs in at nearly 2,400 pages, is informed by a months-long listening tour with nearly 100,000 attendees and nearly 4,000 public comments. A common theme in the input HHS received was the need for flexibility, simplicity, and support for small practices. First, the new payment system creates two pathways. These paths let clinicians pick the right pace for them to participate in the transition from a fee-for-service health care system to one that uses alternative payment models that reward quality of care over quantity of services.

Clinicians will choose between two options:

  • The first path gives clinicians the opportunity to be paid more for better care and investments that support patients. It reduces existing requirements, while still emphasizing and rewarding quality care. In the first year, it also provides a flexible performance period, so that those who are ready can dive in immediately, but those who need more time can prepare for participation later in the year.
  • The second path helps clinicians go further by participating in organizations that get paid primarily for keeping people healthy. For example, they could be part of an Accountable Care Organization where clinicians come together to coordinate high-quality care for the patients they serve. When they get better health results and reduce costs for the care of their patients, the clinicians receive a portion of the savings.

While the AMA is in the process of fully analyzing the regulations, a first review revealed that CMS responded to many of the concerns expressed by physicians about the proposed rule issued last spring. For example:

  • Details are provided about the 2017 transition period announced in September. The only physicians who will experience payment penalties in 2019 are those who choose to report no performance data next year, and those who report for at least 90-days will be eligible for positive payment adjustments.
  • The low-volume threshold that exempts physicians from all performance reporting has been increased from $10,000 in annual Medicare revenue and less than 100 Medicare patients to $30,000 in revenue or 100 patients. CMS estimates that this change will exempt 32.5 percent of physicians and other clinicians from the program.
  • Performance reporting requirements have been further reduced, and the resource use component of the Merit-based Incentive Payment System (MIPS) has been reweighted to zero for 2017.

“We recognize, as described through many insightful comments, that many eligible clinicians face challenges in understanding the requirements and being prepared to participate in the Quality Payment Program in 2017,” Slavitt said in an executive summary of the rule. “As a result, we have decided to finalize transitional policies throughout this final rule with comment period, which will focus the program in its initial years on encouraging participation and educating clinicians, all with the primary goal of placing the patient at the center of the health care system. At the same time, we will also increase opportunities to join Advanced APMs, allowing eligible clinicians who chose to do so an opportunity to participate.”

Evolving Along with Payment Reform

CMS is building the Quality Payment Program to evolve along with the health care system. That’s why it facilitates participation in new payment models. The Affordable Care Act created the Center for Medicare and Medicaid Innovation (Innovation Center) to implement and scale the best ideas from the medical community to improve the quality of care for Medicare beneficiaries while lowering costs. Medicare has a plan for eligible beneficiaries to receive free diabetes prevention services, the quality of hip and knee replacements are being improved while lowering costs, and primary care clinicians are using flexibility to deliver the best outcomes with a payment system that rewards results. CMS intends to broaden opportunities for clinicians, including small practices and specialties, to participate in these kinds of initiatives. CMS is also reviewing reopening some existing Advanced Alternative Payment Models for application to allow more clinicians to join these types of initiatives. In 2018, CMS expects about 25 percent of eligible clinicians will be a part of the second path of Advanced Alternative Payment Models.

Providing Comprehensive Support to Physicians

To further support small practices, MACRA provides $20 million each year for five years to train and educate Medicare clinicians in small practices of 15 clinicians or fewer and those working in underserved areas. Beginning December 2016, local, experienced organizations will offer free, on-the-ground, specialized help to small practices using this funding.

Continuing to Listen

HHS is receiving feedback on the final rule with a comment period and will accept comments until 60 days after the final rule’s release date.

Quick Resource Links

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