Urge Congress to Support Physician Practices During COVID-19

Originally published in the March 23, 2020 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

As Congress works to pass additional emergency funding legislation to combat COVID-19, your help is needed to support medical practices during this public health emergency. Use MGMA’s draft letter to ask Congress to:

• Ensure that every physician and healthcare worker has access to critically needed personal protective equipment (PPE);
• Provide direct financial support to medical practices experiencing an adverse economic impact from suspending visits and procedures unrelated to COVID-19;
• Provide direct financial support to medical practices on the front lines of the COVID-19 public health emergency; and
• Require all payers to provide coverage and payment for telehealth visits (including audio-only) at the same reimbursement as in-person visits.

To send your letter to Congress, click here.

Visit the new MGMA COVID-19 Action Center

Originally published in the March 12, 2020 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

As the Administration, Congress, and broader healthcare community work to combat the spread of Coronavirus Disease 2019 (COVID-19), MGMA will keep medical group practices apprised of the latest developments that could affect patient care and practice operations. Visit the MGMA COVID-19 Action Center for updates on the latest Centers for Disease Control and Prevention and Centers of Medicare & Medicaid Services (CMS) guidance as well as resources that will help your practice during the COVID-19 outbreak.

Follow this link to access the action center.

COVID-19: What to Know as a Healthcare Provider

Originally published in the March 5, 2020 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

As Coronavirus Disease 2019 (COVID-19) continues to spread, it is critical that the healthcare community remains informed on the latest guidance released by the Centers for Disease Control and Prevention (CDC), including CDC clinical criteria for “persons under investigation” and treatment guidelines for confirmed COVID-19 cases. As the Administration takes steps to mitigate growing concerns around the virus, Congress is working to pass supplemental funding to contain and treat its associated illness. The “Coronavirus Preparedness and Response Supplemental Appropriations Act” includes a provision to allow the Secretary of the Department of Health and Human Services to waive certain Medicare telehealth restrictions during the coronavirus public emergency. MGMA Government Affairs will continue to monitor and report on this issue as it develops.

MGMA’s 2020 Advocacy Agenda

Originally published in the February 13, 2020 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

MGMA’s 2020 Advocacy Agenda outlines key issues we are tackling in Washington, such as prior authorization, MIPS, and surprise billing. Ensuring the sustainability of medical group practices is the foundation of our advocacy priorities, and we will continue to work with policymakers to ensure your voice is heard. Help MGMA advocate for group practices by using #MGMAAdvocacy on social media.

CMS Webinar: Overview of MIPS 2020 Performance Period

Originally published in the January 16, 2020 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

CMS will host a 90-minute webinar on Wednesday, Jan. 22 at 2:30 pm ET to provide an overview of the Merit-based Incentive Payment System (MIPS) for the 2020 performance period. Register for the CMS webinar here, and review the MGMA member-benefit analysis of the final 2020 Medicare payment and quality reporting changes for all the details. The analysis is linked under Top Member Resources.

Reminder: 2020 Only a Testing Year for AUC

Originally published in the January 16, 2020 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

Some medical group practices have been told to immediately purchase and use Clinical Decision Support Mechanism (CDSM) software to comply with the Appropriate Use Criteria (AUC) program, with vendors suggesting that claims payment would be impacted in 2020. In a posting on its website, the Centers for Medicare & Medicaid Services (CMS) reiterated that 2020 is an educational and operational testing period and there are no payment consequences this year.

The AUC program will require ordering professionals to consult CDSM software for certain advanced imaging tests and require rendering professionals to include that consultation code on their Medicare claims starting in 2021. Practices are encouraged, however, to plan for implementation of CDSM software and test workflows at some point this year. Access the MGMA AUC Toolkit for additional information on the program.

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 Medicare Cards: It’s Zero Not O

Originally published in the February 27, 2019 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

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.

Medical Practice Issues to Watch in 2019

Originally published in the January 9, 2019 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

2019 promises to be another busy year in healthcare. The 2018 midterm elections shifted the balance of power in Washington as Democrats now hold the gavel in the U.S. House of Representatives, creating a divided Congress with the Republican-held Senate. MGMA has identified the following legislative and regulatory issues critical for medical practices in the coming year. We will keep members apprised of key developments in these areas and their impact on medical practices and will continue to advocate for policies that enable practices to thrive in their mission to furnish high-quality, cost-effective patient care.

1. HHS doubles down on risk

Despite an anemic pipeline of new voluntary Medicare alternative payment models (APMs) trickling out of the Department of Health and Human Services (HHS), Secretary Alex Azar is planning a new approach to accelerate participation in risk-based APMs. Forgoing incremental implementation, the Secretary is expected to unveil new mandatory models in 2019 and to emphasize performance-based risk as a necessary component of any new APM.

MGMA strongly supports voluntary participation in APMs when it makes financial sense for individual practices and disagrees with the Secretary that the way to expedite the move to value-based care is to mandate participation. We will continue to advocate for new opportunities for practices to participate in voluntary APMs and for development of more physician-led models.

2. Regulatory relief from government burdens

It is expected that Congress and the Administration will continue to work toward reducing the regulatory burden on medical practices participating in government healthcare programs. The Centers for Medicare & Medicaid Services’ (CMS’) “Patients Over Paperwork” initiative is one such example. However, this has translated into only modest relief for practices thus far, as 88% of MGMA members polled reported an increase in overall regulatory burden last year. MGMA will continue to make regulatory relief a top advocacy priority in 2019. Keep up with our efforts at mgma.com/regrelief.

3. Kicking back the Stark Law

As part of the effort to accelerate payment innovation, HHS leaders pledge to revisit antiquated fraud and abuse rules such as the Stark Law and Anti-Kickback Statute. In 2019, watch for proposed rules that expand exceptions and safe harbors to protect value-based arrangements and benefit providers willing to take on performance-based risk.
While a push to simplify Medicare compliance rules is welcomed, it is likely that congressional intervention will be necessary to achieve meaningful reform. It remains to be seen if Congress will also prioritize this issue in 2019.

4. Surprise! Here is a medical bill you didn’t expect

Medical practices can expect to see a push to curb surprise medical bills, including efforts to empower patients and consumers through improved access to healthcare cost information. The sticker shock of surprise hospital bills continues to make headlines and draw bipartisan attention in Congress, making this issue ripe for legislative action in 2019.

5. A spoonful of new regulations to help drug prices go down

With a new Congress and support from the Administration, reducing Medicare drug prices is on the action list for 2019. For physician-administered drugs, one proposal seeks to curb the price of drugs in Part B by tying prices to a new International Price Index, create new private-sector vendors to supply practices with drugs, and set drug administration cost as a flat fee. CMS is also looking to give Part D drug plans greater flexibility to negotiate drug prices in protected classes.

6. The stakes are higher in MIPS

Implementation of the Merit-based Incentive Payment System (MIPS) continues to ramp up. In 2019, MIPS performance will determine whether clinicians receive a positive or negative payment adjustment of up to 7% on 2021 Medicare reimbursement. Medicare is accelerating cost accountability for MIPS clinicians by increasing the cost component to 15% of the overall MIPS score and introducing episode-based measures. The performance threshold required to avoid a payment penalty also doubles from 15 to 30 points in 2019. With more on the line this year, it is critical that MGMA members prepare their practices for success. Visit mgma.com/macra for helpful resources.

7. Data interoperability a priority for feds

The Office of the National Coordinator for Health Information Technology (ONC) is expected to release regulations to meet requirements of the 21st Century Cures Act and facilitate improved data sharing between healthcare entities. ONC will define and seek to discourage “information blocking,” develop a framework to facilitate data movement between heath information exchange entities, and release specifications for the use of apps to foster data exchange between different providers and between providers and patients. The goal of using apps, a component of MIPS and Stage 3 Meaningful Use, is to permit practices to efficiently and securely move administrative and clinical data via their EHR.

8. Cybersecurity continues to be a top practice concern

Medical practices can be a prime target for phishing and other cybersecurity attacks because they possess valuable information assets (patient clinical and financial data) and often have inadequate cybersecurity protections. HHS’ HIPAA enforcement arm is expected to ramp up audits and fines in 2019. Medical practices should protect both their data and business continuity by completing a comprehensive risk assessment, identifying vulnerable areas of the organization, and taking the steps necessary to mitigate risk. Check out MGMA security resources to prepare your practice this year.

9. Site-of-service payment differentials remain a target

Policymakers will continue the trend toward site-neutral payments with the goal of equalizing Medicare payments for the same services across clinical sites. Medicare expanded this policy through 2018 rulemaking by phasing-in payment reductions for clinic visits at hospital outpatient departments (HOPDs), including HOPDs excepted from previous site-neutral payment rules. In addition to saving money for patients and the government, site-neutral payments are viewed as a policy lever for increasing market competition, eliminating the incentive for hospitals to purchase freestanding clinics and leveling the playing field.

10. “Repeal and replace” is out, “Medicare for all” is in

This shift in power within Congress will recast the role the federal government plays in healthcare in 2019. With “Medicare for all” a key platform for many progressives during the 2018 primaries, the politicized debate over a single-payer health system shows no signs of slowing down and will likely gain steam ahead of 2020 elections.
Passage of any major health reform bill is highly unlikely anytime soon. However, as presidential contenders begin campaigning for the 2020 primaries, universal healthcare will almost certainly become a point of debate.

Dems take the House in 2018 midterms: What’s next for healthcare

Originally published in the November 7, 2018 issue of MGMA’s Washington Connection
Reprinted with permission from MGMA

Following last night’s elections, Democrats won the U.S. House of Representatives for the first time since 2010, while Republicans will likely increase their numbers and maintain control of the Senate. Healthcare issues dominated the campaign cycle, yet it remains to be seen what role healthcare will play in agenda-setting for the upcoming Congress. One issue now unlikely to advance on the legislative front is the repeal of the Affordable Care Act (ACA). Democrats have solidified their ability to block any ACA repeal bill, and Republican leaders appear open to supporting aspects of the ACA such as protections for pre-existing conditions.

The Democratic victory in the House means new leaders will chair key committees overseeing health policy. Nancy Pelosi (D-Calif.) is expected to reclaim her role as Speaker of the House and has promised to make drug pricing a priority for the next Congress. The Trump administration has similarly prioritized this issue, but it is unclear whether leaders from the administration and Senate will work together with House leadership on their shared priority to lower drug costs.