Medicare Finalizes 2023 Payment and Quality Reporting Changes

Originally published in the November 1, 2022, issue of MGMA’s MGMA Regulatory Alert
Reprinted with permission from MGMA

The Centers for Medicare & Medicaid Services (CMS) released the final 2023 Medicare Physician Fee Schedule (PFS) rule this afternoon, which in addition to major payment implications, includes changes to the Merit-based Incentive Payment System (MIPS) and alternative payment model (APM) participation options and requirements for 2023. The final rule:

• Sets 2023 Medicare payment rates for physician services. For 2023, CMS finalized a conversion factor of $33.0607 and $20.6097 for Anesthesia (a decrease of -4.47% and -4.42%, respectively, over final 2022 rates);
• Finalizes implementation of provisions of the Consolidated Appropriations Act, 2022 that extend the application of certain Medicare telehealth flexibilities for an additional 151 days after the end of the COVID-19 public health emergency (PHE), such as allowing telehealth services to be furnished to patients in their homes;
• Extends flexibilities to permit split/shared E/M visits to be billed based on one of three components (history, exam, or medical decision making) or time until 2024;
• Expands access to behavioral health by permitting marriage and family therapists, licensed professional counselors, and others to furnish behavioral health services under general supervision instead of direct;
• Maintains the MIPS performance threshold at 75 points for the 2023 MIPS performance year/2025 payment year;
• Adds five new MIPS Value Pathways related to nephrology, oncology, neurological conditions, and promoting wellness, for voluntary reporting beginning in 2023; and
• Creates an advanced incentive payment pathway for certain low-revenue, new entrant accountable care organizations to bolster participation in the Medicare Shared Savings Program.

MGMA submitted detailed comments in response to the proposed rule in September. Be on the lookout for a more detailed analysis of the final changes to physician payment policies and the Quality Payment Program (QPP) in the coming weeks.

Additional information about the final rule is available in the PFS fact sheet and the QPP fact sheet.

Start Strong in 2020: Important Dates for Physician Practices

Originally published in the December 19, 2020 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

Transitioning to a new year means important federal program deadlines and launches. Below are key dates that executives should know as they prepare their medical practice for success in 2020.

DEC. 31

• Check MIPS 2019 eligibility by year’s end
  Clinicians are encouraged to confirm their 2019 Merit-based Incentive Payment System (MIPS) eligibility status by using the QPP Participation Status Tool to determine whether they must report data in 2020. The Centers for Medicare and Medicaid Services (CMS) recently concluded its second review of Part B claims and PECOS data spanning Oct. 1, 2018 through Sept. 30 of this year.
• Deadline to submit MIPS hardship and exception application
  Promoting Interoperability and Extreme and Uncontrollable Circumstances Exception applications for the MIPS 2019 performance year must be submitted by Dec. 31. MIPS participants in FEMA-designated disaster areas are automatically exempt from reporting and will have all four performance categories re-weighted to 0% of their final score.
• Deadline to review and dispute program year 2018 Open Payments data
  Visit the CMS Open Payments website to review data submitted from drug and device manufacturers describing any payments made to physicians in your practice. Clinicians have until the end of the year to dispute any incorrect information.

JAN. 1

• New 2020 Medicare payment rules and MIPS requirements
  The 2020 Physician Fee Schedule begins, which includes payment updates for Medicare services, changes to billing guidance for certain codes, and modifications to reporting requirements under MIPS. These details are outlined in MGMA’s member-exclusive analysis.
• Use of MBI on Medicare claims starts
  Starting Jan. 1, Medicare claims are required to contain the Medicare Beneficiary Identifier (MBI) in order to be processed. For patients who do not present with their new card, practices can get their MBI via your Medicare Administrative Contractor. Members can access the MGMA New Medicare Card Toolkit to prepare for the transition.
• AUC education and testing period begins
  Jan. 1 marks the start of the one year educational and operations testing period for the CMS Appropriate Use Criteria (AUC) program. Download the member-benefit AUC Toolkit to learn more.

JAN. 2

• MIPS 2019 data submission period starts
  2019 MIPS performance data can be submitted to CMS from Jan. 2 through March 31. Authorized representatives can submit clinician and practice data via the QPP webpage.

JAN. 22

• Close of Primary Care First and Kidney Care Choices application period
  Jan. 22 is the deadline to apply for the Primary Care First (PCF) Model and Kidney Care Choices (KCC) Model. PCF will be offered in 26 geographic regions starting in 2021, and the KCC Implementation Period will begin later in 2020. MGMA will share links to several informative resources prior to the deadline for practices seeking to understand whether these models are right for them.

New MGMA MACRA rule executive summary

Originally published in the November 9, 2016 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

MGMA’s new executive summary condenses this extensive regulation to six pages of key issues impacting medical practices. On October 14, the Centers for Medicare & Medicaid Services (CMS) released a final rule implementing the new Merit-Based Incentive Payment System (MIPS) and advanced alternative payment models (AAPMs), which take effect on Jan. 1, 2017. As a direct result of MGMA advocacy, the final quality payment program (QPP) rule significantly mitigates the administrative burden for group practices in MIPS and continues to increase opportunities to move away from MIPS into APMs. To help physician practice leaders understand the final policies and prepare for the transition to MIPS and AAPMs, MGMA Government Affairs created a detailed  resource, which answers commonly asked questions about these new programs and outlines five action steps to consider ahead of 2017.