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Many pathologists may not know that 15% of your Merit-based Incentive Payment System (MIPS) bonus is based on affirming that you do certain quality improvement activities in your practice. The CAP has identified several Improvement Activities options to help members get the most of their 2017 MIPS reporting tool.

Improvement Activities are designed to improve clinical practice or care delivery that, when effectively executed, lead to improved outcomes. In order to avoid a penalty, and potentially seek a bonus for the 2017 reporting year, eligible clinicians must attest to completing 1-2 improvement activity for at least 90 days. The CAP identified a subset of the improvement activities that are most pertinent to pathologists (e.g. reports to referring physicians, maintenance of certification part IV, etc.) The full detailed Improvement Activities list, with suggestions for documentation, is CAP member-only content.

The CAP suggests that pathologists reach out to their billing companies and inquire how their improvement activities will be reported. If you need a solution to report your improvement activities for 2017, the CAP’s 2017 MIPS Reporting Solution can help.

Pathologists can use the CAP 2017 MIPS Reporting Solution, including eight pathology-specific quality measures developed by the CAP and all 92 improvement activities included in the MIPS program. The CAP and its registry vendor partner FIGmd are offering pathologists free access to the 2017 MIPS Reporting solution to aim for a full bonus in MIPS.

Pathologists can use the 2017 MIPS Reporting Solution to maximize their opportunity to increase their Medicare payment.

With the 2017 MIPS Reporting Solution, pathologists can fully meet program requirements.

  • If you currently report quality measures through billing or other ways: Increase your bonus potential by attesting for the improvement activities.
  • If you have not decided how to report for MIPS 2017: Report on quality measures for a 90-day period–or a full year of patients–and attest to improvement activities to increase your payment potential and, at a minimum, avoid a payment penalty.

Contact CAP registry staff if you have questions about the 2017 reporting option.

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Legislation that would repeal Medicare's Independent Payment Advisory Board (IPAB) has passed the US House, but its future remains uncertain as Congress debates how to pay for it. The CAP supports repeal of the IPAB, which was established under the Affordable Care Act as an effort to control Medicare costs. The CAP called on congressional leaders to pass this legislation.

HR 849, the Protecting Seniors' Access to Medicare Act of 2017, passed the House by a vote of 307 to 111. The IPAB has the authority to make recommendations regarding Medicare cuts without Congressional oversight or input. In addition, IPAB proposals are considered under fast-track procedures that limit Congress's ability to modify cuts to Medicare and automatically puts proposals in effect if Congress fails to act.

While the board was never constituted, cuts still could have been triggered under the law if the Centers for Medicare and Medicaid Services’ (CMS’) actuary determined that spending was too high. Though Medicare spending has not yet reached a high enough threshold to trigger the cuts, it is projected that current spending levels could have triggered cuts beginning in 2021.

Critics, including many in the medical community, have opposed the IPAB because they feel it circumvents congressional authority to debate, manage and legislate changes to the Medicare program. Rep. Phil Roe (R-TN), the bill's sponsor, called the IPAB a gross overreach of power and said he has "grave concerns that IPAB could drastically cut Medicare benefits with no congressional oversight."

HR 849 has been referred to the Senate for consideration. The Congressional Budget Office estimates the cost of repealing IPAB at $17.5 billion over 10 years. There also are two separate bills to repeal the IPAB pending in the Senate, but these bills have not yet been considered by the Senate Finance Committee. Similar legislation has passed the House in previous years but has failed to advance in the Senate.

The CAP will follow developments on the bill and will report on them in future issues of STATLINE.

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The CAP commended the release of a report and recommendations by President Trump's Commission to combat drug addiction and the opioid crisis on November 1.

The President's commission outlined 56 recommendations on steps the administration should take to combat the opioid crisis primarily focused on improving physician prescribing practices and treatment paradigms for patients. Of the 56 recommendations, two recommendations impact forensic pathologists. Those recommendations seek to improve data collection for forensic pathologists and the use of toxicology to identify new psychoactive opioids.

In a statement, CAP President R. Bruce Williams said, "the CAP encourages the President's commission to further recognize the pathologist as an essential partner in the medical response to the opioid crisis. In addition, we encourage the administration to allocate resources supporting the development of opioid drug proficiency testing programs, including those dealing with the rapidly changing field of synthetic designer drugs, and medical examiner programs to diagnose deaths due to drug overdose."

In addition, the CAP provided a formal comment letter on the draft report detailed a full list of recommendations to further address the opioid crisis. Additional updates from the commission will be reported in future STATLINE editions.

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On November 2, the CAP issued a special STATLINE Alert outlining the impact to pathologists under the new regulatory and reporting rules for 2018, including the 2018 Medicare Physician Fee Schedule and the final 2018 Quality Payment Program (QPP) reporting requirements.

On November 1 and 2, the CMS released a number of regulatory and reporting rules affecting pathologists. The CAP's efforts to protect the value of pathology services were adopted by the CMS in two final Medicare regulations affecting reimbursements next year—the final 2018 Medicare Physician Fee Schedule and the final 2018 Hospital Out Patient Prospective Payment System rule. Moreover, the CAP continues to ensure that pathologists can successfully participate in the Medicare QPP as the CMS adopted the CAP's recommended changes to the 2018 QPP final rule.

Final 2018 Medicare Physician Fee Schedule

The CAP successfully developed and advocated for values to protect therapeutic apheresis, pathology consultation, and other pathology services targeted for revaluation, resulting in the Medicare program accepting all of the physician work recommendations for pathology services used to calculate professional component and global payment rates in the final 2018 Medicare Physician Fee Schedule. Details of the impact on pathology services resulting from this final rule are detailed in the CAP's 2018 Medicare Physician Fee Schedule Impact Table.

Learn more about the impact of the 2018 Physician Fee Schedule and the Medicare Hospital Outpatient Prospective Payment System final rule by registering for a webinar on November 9.

Final 2018 Quality Payment Program Rule

Due to the CAP's work to develop quality measures and create opportunities for pathologists to improve performance in Medicare's quality programs, the CMS estimates that the total positive adjustment for pathology will be $5.6 million in 2020 from QPP participation.

On November 2, the CMS published its final 2018 QPP rule updates with a comment period to its QPP rule that included updates advocated for by the CAP. Prior to the release of the final rule, the CAP engaged with the CMS and advocated for several changes.

Learn more and prepare for changes next year by registering for our webinar on November 29.

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Thursday, November 9, 2017
12:00 PM CT

Learn more about pathology reimbursement changes in the final 2018 Medicare Physician Fee Schedule during a CAP webinar on November 9 at 1 pm ET/12 pm CT.

The CAP engages with the CMS directly to protect the value of pathology services for its members and through its direct work with the AMA Specialty Society Relative Value Scale Update Committee (RUC) for physician work relative values. Led by Donald Karcher, MD, FCAP, Chair on the Council on Government and Professional Affairs, W. Stephen Black-Schaffer, MD, FCAP, Chair of the Economic Affairs Committee, and Jonathan Myles, MD, FCAP, of the Board of Governors, this 60-minute webinar will review how the final fee schedule will affect services, such as therapeutic apheresis, pathology consultations during surgery, and tumor immunohistochemistry in 2018.

Register today.

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Wednesday, November 29, 2017
12:00 PM CT

As the CMS has now finalized rules for the 2018 Quality Payment Program, learn how you can prepare and plan for next year's MIPS performance period.

In 2018, most pathologists will need to take action to stop penalties from reducing future Medicare payments for their services and nearly all pathologists will be required to participate in MIPS.

On November 29, the CAP will host a 60-minute webinar to discuss 2018 options for preventing Medicare penalties and, in certain cases, increase reimbursements in 2020. The webinar will begin at 1 PM ET and will be moderated by Donald Karcher, MD, FCAP, Chair of the CAP Council of Government and Professional Affairs. Dr. Karcher will be joined by W. Stephen Black-Schaffer MD, FCAP, Chair, of the CAP Economic Affairs Committee and; Diana Cardona, MD, FCAP, Chair of the CAP Economic Affairs Measures & Performance Assessment Subcommittee, who will discuss how these proposed Medicare program changes under the Quality Payment Program will affect pathologists in 2018.

Register today.

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Registration is open for now the 2018 CAP Policy Meeting–Protecting the Practice of Pathology and Our Patients.

The annual CAP policy meeting, which is set for from April 30–May 2 at the Washington Marriott in Washington, DC, enables CAP members to connect with government leaders and policy experts to discuss the impact of federal regulation on their pathology practices.

New regulations are taking shape that will impact pathology reimbursements for years to come. Attendees at the CAP Policy Meeting will receive the latest information and analysis on the implementation of new Medicare and laboratory regulations. The CAP is actively engaged in the legislative and regulatory arenas on the critical issues facing pathology and laboratory medicine, including physician payment reform, reducing regulatory burdens, and improving health care quality.

The CAP Policy Meeting will also include meetings with members of Congress and their staff during the CAP’s Annual Hill Day on May 2, which is the specialty's opportunity to focus on the federal issues most important to pathologists now and in the future.

The CAP Policy Meeting is a benefit of CAP Membership. There is no fee to register.

Register for the 2018 Policy Meeting.

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