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• CAP Urges Medicare Agency to Consider Pathologists Concerns When Overhauling Shared Saving Program
• URAC, NCQA Urged to Adopt Better Health Plan Network Adequacy Oversight
• At CAP18, Discussing the Pathologists’ Role to Confront the Opioid Epidemic
• Start Preparing for 2019 Medicare Payment Changes: Upcoming Webinar

To ensure that pathologists can fully participate in Alternative Payment Models (APMs), the CAP urged the Centers for Medicare and Medicaid Services (CMS) to address issues related to performance-based risk, quality measures, and promoting interoperability when finalizing 2019 regulations for the Medicare Shared Savings Program. The CMS recently proposed to overhaul the Medicare Shared Savings Program, under which the vast majority of Medicare’s Accountable Care Organizations (ACOs) operate.

In the CMS proposed regulation published on August 9, the Medicare agency outlined plans for providers participating in Medicare’s Shared Savings Program to assume more downside risk in the form of payment penalties when organizations do not produce savings. However, the CAP in an October 15 comment letter to the CMS reinforced its position that the CMS should first focus on increasing opportunities and incentives for specialty physician involvement in shared savings programs before unnecessarily pursuing greater risk. “Though there are certainly some new improvements offered by the CMS in this proposed rule, the reduction of the risk-free years and lowered maximum shared savings rate changes do not appear in line with that objective,” the CAP said. Changes to the Shared Savings Program that would discourage ACO formation could create unnecessary hurdles for pathologists to pursue this path.

The CAP also engaged with the CMS on how to appropriately measure non-patient-facing providers, including pathologists, and recommended that alternate measures are necessary for non-patient-facing clinicians. With extensive experience as a quality standards-setting organization, the CAP will continue to engage with the CMS to establish appropriate measures for pathologists.

The CAP urged the CMS to consider the contributions of diagnostic specialties in the exchange of electronic patient data. Most laboratory information systems (LIS) cannot attain the Certified Electronic Health Record Technology (CEHRT) status and pathologists face unique challenges in meeting many health information technology requirements in both the Quality Payment Program’s Promoting Interoperability performance category and the APM CEHRT use thresholds. Moreover, electronic health record (EHR) vendors create barriers to access patient information, which interfere with and materially discourage physician and patient access to information and integration among LIS. The CAP advised the CMS to consider these concerns when finalizing the requirements.

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The American College of Radiology (ACR) and the CAP called on URAC and the National Committee for Quality Assurance (NCQA) to take public policy actions on deficiencies in health plan network adequacy standards. In letters sent to URAC and NCQA on October 9, the hospital-based physician groups urged the two health plan accreditors to set oversight standards to ensure that health plans maintain adequate numbers of in-network providers at hospitals.

These suggested policy actions include following network adequacy standards set in American Medical Association (AMA) policy, state regulatory requirements found in the National Association of Insurance Commissioners Health Benefit Plan Network Access and Adequacy Model Act, the Federal Qualified Health Plan Application Standard, and state laws and regulation in California, Louisiana, and New Hampshire.

The CAP and the ACR are also supported by several health care organizations and patient advocacy groups on network adequacy standards reform. In a single public policy declaration, the groups called for state and federal regulators to ensure patients have reasonable and timely access to in-network hospital-based physician specialties. In addition to the CAP and the ACR, the following organizations have signed on to the declaration: Society of Hospitalist Medicine, National Brain Tumor Society, Leukemia and Lymphoma Society, National Kidney Foundation, Congenital Adrenal hyperplasia Research, Education & Support (CARES) Foundation, Epilepsy Foundation, Bladder Cancer Advocacy Network, Breast Cancer Action, Ovarian Cancer Research Fund Alliance, and the Kidney Cancer Association.

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Considering the CAP’s advocacy to support pathologists addressing the opioid crisis, a session at CAP18 will facilitate a discussion between policymakers and thought leaders on issues related to the epidemic. The session entitled The Role of Pathologists in Addressing the Opioid Epidemic (STA009) will feature Barbarajean Magnani, PhD, MD, FCAP, chair of the CAP’s Toxicology Committee, and AMA Chair-Elect Jesse M. Ehrenfeld, MD, MPH. The session is also designed to highlight how we can work together with federal policymakers to better understand and monitor the factors driving the opioid epidemic and the effects on practicing clinicians.
Registration is still open for other timely Advocacy sessions at CAP18:

Educational Sessions

• MACRAscopic Analysis of the New Quality Payment Program: Maximize Reimbursement While Demonstrating Value (S1620)
• How Is My Payment Determined for Pathology Services? Non-CME course (STA008)
• The CAP’s Policy and Advocacy Agenda (STA010)
• The Role of Pathologists in Population Health: An Interactive Discussion (STA011)
• What You Need to Know About the CAP’s Pathologists Quality Registry Non-CME course
• Lunch Roundtables
  • Current Payment Policy Challenges in Pathology Practice (R1691)
  • My Surgical Pathology and Cytopathology Coding Dilemmas: Getting It Right—An Advanced Discussion (R1690)

Registration is open for vital CAP policy and advocacy courses and roundtable discussions during CAP18.

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In the next few weeks, the CMS will finalize the 2019 Medicare Physician Fee Schedule and Quality Payment Program changes that will impact Medicare pathology payment and services next year. The CAP is offering one of its most popular webinars - 2019 Final Medicare Policy and Payment Changes - where CAP experts will review the final regulation changes on November 9, 2018, at 11 AM ET.
Presenters are:

Donald S. Karcher, MD, FCAP
Chair of the Council on Government and Professional Affairs

Emily E. Volk, MD, FCAP
Vice-Chair of the Council on Government and Professional Affairs
Chair of the CAP Clinical Data Registry Ad-Hoc Committee

W. Stephen Black-Schaffer MD, FCAP
Chair of the CAP Economic Affairs Committee

Register today.

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