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April 10, 2018
CAP, CMS Discuss Ways to Relieve Burdens of MIPS Reporting
Recently CAP leaders met with top officials at the Centers for Medicare & Medicaid Services (CMS) to discuss the challenges pathologists face when participating in Medicare’s Quality Payment Program (QPP), and to seek ways to reduce the administrative burden of complying. During the meeting, the CAP advocated for specific changes and committed to working with the CMS on solutions so pathologists can participate fully and be successful in the program.
Measure Development and Performance Assessment Subcommittee Chair Diana M. Cardona, MD, FCAP, led the two-hour meeting on behalf of the CAP. The conversation focused on the challenges pathologists, who are mostly classified as non-patient-facing clinicians, encounter in participating in the Merit-Based Incentive Payment System (MIPS) due to the burden associated with collecting and reporting on measures.
Pathologists also are unable to participate in the Advancing Care Information and Cost categories and the weight of those categories is reweighted to the Quality category. Thus, the Quality category carries a disproportionate amount of weight in MIPS for pathologists. As such, the CAP urged the CMS to consider ways in which pathology measures can achieve maximum scoring potential. The CAP asked that the CMS collaborate with the CAP on strategies to close the gap that is currently evident in pathology measures as the CAP looks to bolster the number and type of quality measures available to pathologists for reporting in MIPS.
During the meeting the CMS expressed their interest to work with the CAP on regulatory relief for pathologists and will continue to engage with the CAP on ways to reduce QPP reporting burdens. These include strategies to reduce the proportion of weight on the Quality category, ensure there is a menu of available quality measures for MIPS reporting that apply to pathologists, and warrant that those measures have the potential for maximum scoring. The CMS also responded favorably to considering pathologists’ participation in the Advancing Care Information category. This would go a long way in reducing pathologists’ reliance on the Quality category and would give credit to pathologists, as they populate Electronic Health Records (EHRs) with important patient information. Finally, the CMS agreed to work with the CAP to reduce the complexity of attesting to the Improvement Activities (IA) category, so that pathologists can easily attest to the myriad improvement activities already being done to ensure the highest quality in the lab.
Check Your MIPS Eligibility for 2018
Pathologists can now check their eligibility for the 2018 MIPS performance year after the CMS released an update to an online tool that can confirm participation status in the Medicare pay for performance program earlier this month.
The CMS MIPS Participation Lookup Tool is available to check 2018 MIPS reporting eligibility. To look up eligibility for MIPS 2018 reporting, a physician needs to enter his or her National Provider Identifier. The CMS tool will then reveal if you are eligible or exempt from 2018 MIPS reporting.
The 2018 Participation Lookup Tool for Alternative Payment Model (APM) participants will be updated later this year.
CMS Changes To Low-Volume Threshold
To reduce burdens on small practices, the CMS changed the eligibility threshold for 2018 to make more small practices and clinicians exempt from reporting. Therefore, if you were not exempt from MIPS in 2017, you may now be exempt from reporting this year. It is beneficial to check your eligibility again for 2018.
Based on the 2018 regulation, clinicians and groups are now excluded from MIPS reporting if they:
- Billed $90,000 or less in Medicare Part B allowed charges for covered professional services under the Physician Fee Schedule (PFS), or
- Furnished covered professional services under the PFS to 200 or fewer Medicare Part B-enrolled beneficiaries
To be included in MIPS for the 2018 performance period, you need to have billed more than $90,000 in Medicare Part B allowed charges for covered professional services AND furnished services to more than 200 Medicare Part B enrolled beneficiaries.
Congress Funds Programs to Combat Opioid Epidemic, Including State Crime Labs
Congress designated funding to help combat the opioid epidemic and state crime laboratories in a $1.3 trillion omnibus spending package enacted on March 23.
In January, the CAP advocated for additional funding to help with the challenges the opioid epidemic has brought to the forensic pathology community. An increase in overdoses of heroin and synthetic drugs like fentanyl has led to a backlog of autopsies needed to be performed at state crime laboratories by forensic pathologists.
The CAP asked for additional funding to help these state crime laboratories and facilities that conduct autopsies done by medical examiners and coroners.
“As drug overdose deaths in America have reached crisis proportions, the federal government has responded with prevention, interdiction, and treatment, but has not addressed the forensic element of the prevention or law enforcement aspect of the crisis,” the CAP said in the January letter to congressional appropriators. “In particular, the forensic science community is being forced to absorb the massive increase of cases that are now overwhelming the nation’s federal, state, and local medical examiners and crime labs. The issue of how to equip the forensic community to respond is quite complex and requires more than just funding.”
In the omnibus, the Senate appropriation request from the CAP for the Coverdell National Forensic Science Grant was funded at $30 million. Of that, $17 million is for grants to reimburse state, local, and forensic science laboratories, and medical examiner and coroner offices to help address backlogs of untested samples of heroin, fentanyl, and associated synthetic drugs, and to conduct autopsies and toxicology testing related to suspected drug overdose deaths from these drugs as a result of the opioid crisis.
Be Heard at the Upcoming 2018 Policy Meeting
Can pathologists really make a difference in helping to drive change? Yes, and at the annual 2018 Policy Meeting, CAP members will meet with House and Senate offices to discuss the issues important to pathologists and their patients.
"Nobody understands better than you do," says Jared Abbott, MD, PhD, FCAP. Watch Dr. Abbott discuss how his practice has benefited by engaging with policy makers at both federal and state levels in educating others about the value pathology brings to patient care.
Like Dr. Abbott, CAP members can hear keynote speakers Judy Woodruff, Charlie Cook, and William Kristol provide a unique perspective on the potential impact of the 2018 mid-term elections at the Policy Meeting, which is scheduled April 30 – May 2, at the Washington Marriott in Washington, DC.
Ms. Woodruff is the anchor and Managing Editor of “PBS NewsHour,” and has covered politics and other news for more than four decades at CNN, NBC, and PBS. While Mr. Kristol is the editor-at-large of The Weekly Standard, is a regular on ABC’s “This Week” and on ABC’s special events and election coverage, and appears frequently on other leading political commentary shows. Moreover, Mr. Cook is editor and publisher of The Cook Political Report and a columnist for National Journal magazine. Mr. Cook founded The Cook Political Report in 1984 and became a columnist for Roll Call, the Capitol Hill newspaper.
The Policy Meeting begins Monday, April 30 and ends with Hill Day on Wednesday, will take place at the Washington Marriott in Washington, DC, is a benefit of CAP membership and there is no fee to register. View the full meeting agenda and register today.
Watch the Webinar: Policy Meeting 101—What to Know Before You Go
Wednesday, April 4, 2018 1:00 PM ET/ Noon CT
If you are one of the many pathologists concerned about practice or patient care implications from emerging policies and regulations, watch this webinar to learn the most effective ways you can ensure your voice is heard in Washington on issues that matter to you.
Gain insight on best practices and understand the difference you can make by engaging with your colleagues in protecting scope of practice and the quality of care for patients.
Already registered to attend this year’s Policy Meeting? This is a great webinar for CAP members who are attending the Policy Meeting, especially those attending for the first time, as you’ll gain a general understanding of grassroots advocacy before you arrive in Washington.
Whether you are DC bound or looking to get involved in your district, you’ll want to hear from experienced advocates Donald Karcher, MD, FCAP, Chair of the Committee of Government and Professional Affairs, Joe Saad, MD, FCAP, Federal and State Affairs Committee Chair, and moderator Michael Giuliani, CAP Advocacy Senior Director.
Watch it today.