Tag Archives: physician reimbursement

What Happened in Washington This Week

By Brittney Fairman, MPS, MA, ACCC Policy Analyst

U.S. CapitolIt’s been quite a week in Washington, D.C.  Let’s recap.

On Wednesday, July 12, the Centers for Medicare & Medicaid Services (CMS) held the latest in a series of webinars explaining the agency’s proposed rule for CY 2018 updates to MACRA’s Quality Payment Program. If you missed ACCC’s webinar on the implications of this proposed rule, members can access the webinar, presentation slides, and a summary [login required].

On Thursday morning, July 13, U.S. Senate Republicans unveiled their revised draft of the Better Care Reconciliation Act of 2017 (BCRA). The updated bill is the latest effort to repeal and replace the Affordable Care Act (ACA), and we continue to have concerns about the erosion of protections for cancer patients in the exchange marketplaces. ACCC is continuing to monitor the effort on the Capitol Hill and measure the evolving legislation against ACCC’s health reform principles.

Then later that same day, the Centers for Medicare & Medicaid Services (CMS) released the proposed CY 2018 Hospital Outpatient Prospective Payment System rule and CY 2018 Physician Fee Schedule rule. ACCC is currently analyzing both rules and will provide in-depth information to members on the impact on oncology. At first glance, the proposed, significant cuts to hospitals in the 340B Program and to new outpatient facilities cause concern, particularly for small, rural cancer programs and programs in vulnerable communities without other sources of healthcare. Stay tuned for information on the date and time of an upcoming ACCC members-only webinar on these proposed rules.

Also Happening on Capitol Hill
So this week, while much of the nation’s attention has been focused on Congressional action on ACA repeal and replace, and many healthcare providers awaited CMS’s release of the proposed 2018 Medicare rules, it’s important to note that another significant piece of legislation moved forward on Capitol Hill. On July 12, the U.S. House of Representatives passed the FDA Reauthorization Act (HR 2430). This legislation includes important bills for cancer care, including the Research to Accelerate Cures and Equity (RACE) Act and reauthorization of the Prescription Drug User Fee Act (PDUFA), which allows the FDA to collect fees from drug manufacturers to fund the new drug approval process. The User Fee Program plays an important role in the timely review of new drug applications and patients’ ability to access novel therapies.

The “RACE” Act is a bill which has important implications for the fight against childhood cancer. The legislation specifically updates the 2003 Pediatric Research Equity Act (PREA), which requires studies of adult drugs in adolescents during a drug’s development process.

PREA has experienced success in providing important information on a drug’s use in children in hundreds of cases; but, it has not yet been applied to pediatric cancer drugs. It is well known within the oncology community that many pediatric cancer patients are typically treated with “off-label” adult drugs. Under the RACE act, the FDA will be given authority to require a pediatric investigation into adult drugs if those drugs use molecular targeting and that same target is “substantively relevant” to the continuance of a pediatric cancer. If passed in the U.S. Senate, this act will permit clinicians to know the dosage, safety and efficacy in pediatrics and grant accurate labeling for use on children. Additionally, the RACE act will mandate that molecular targeting drugs be given an orphan designation to go through a pediatric investigation.

As summer in Washington continues to heat up, ACCC is closely monitoring legislation on Capitol Hill and performing an in-depth analysis of CMS’s proposed rules for 2018. Stay tuned for updates.

 

CMS Eases MACRA Quality Payment Program Timeline

By Leah Ralph, Director of Health Policy, ACCC

Centers_for_Medicare_and_Medicaid_Services_logoIn response to considerable pressure from industry stakeholders, medical groups and policymakers, the Centers for Medicare & Medicaid Services (CMS) announced last week that it would provide increased flexibility for practices to report out and comply with new data and performance requirements under the Quality Payment Program (QPP), created by the Medicare Access and CHIP Reauthorization Act (MACRA) passed last year.

In a blog post titled “Plans for the Quality Payment Program in 2017: Pick Your Pace,” Acting CMS Administrator Andy Slavitt lays out four pathways to compliance with the new Quality Payment Program (in order of easiest to the hardest):

  • Report some data.  Providers can avoid a negative penalty by submitting some data as required by the Quality Payment Program, including data from after January 1, 2017. CMS states this option is “designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019.” This option allows you to avoid a negative payment adjustment in 2019.
  • Participate for only part of the calendar year. Providers may submit data as required by the Quality Payment Program for a reduced number of days (not the whole year), and the performance period could begin after January 2017. Under this option, you could still qualify for a small positive payment adjustment in 2019.
  • If you’re ready to go in 2017, participate for the full calendar year. For practices that are ready to go and choose this option, their performance period will begin January 1, 2017, and they will submit data under the Quality Payment Program for a full year. These practices will qualify for a modest positive payment adjustment in 2019. CMS expects many practices will be able to do this.
  • Participate through an Advanced Alternative Payment Model (APM).** While the three previous options would fall under the Merit-Based Incentive Payment System (MIPS) track, the fourth option allows providers who are receiving a certain percentage of Medicare payments or seeing a certain number of Medicare patients through a qualifying APM (the provider is taking two-sided or “more than nominal” risk) to participate through the Advanced APM track. These providers would qualify for a 5% incentive payment in 2019 in addition to any savings produced through the APM and would not be subject to MIPS requirements. (**Remember CMS lays out a very high bar to qualify for the APM track in the proposed rule: 90% of physicians are expected to choose MIPS).

Until 2019, physicians will see an annual 0.5% increase in payments, at which point payments will then be determined by performance in the Quality Payment Program either through MIPS or an advanced APM.

CMS has said the decision to provide leniency was in recognition of the “wide diversity of physician practices.” The agency has also said it is considering alternative start dates, shorter performance periods, increased flexibility for small or rural practices, and finding other ways for physicians to get more experience with the program requirements before being penalized.

CMS originally proposed that providers begin to report on measures outlined under the Quality Payment Program in January 2017 but that payments would not reflect that performance period until 2019. However with the new guidance from CMS, the easiest option essentially does not require real provider participation in 2017, but allows providers to test whether their systems are ready to fully participate in the future. While the details of the measures will remain unclear until a final rule is released, the Quality Payment Program will require practices to submit information on quality measures, how they use technology, and what improvement activities they are undertaking.

Through our comments to the agency in  June, ACCC advocated for increased flexibility and more time for physicians to prepare for undertaking the new requirements under the Quality Payment Program. We also asked the agency to restructure the APM requirements so that they are more achievable.

We commend CMS for releasing flexibility prior to a final rule on MACRA, which we expect to see later this fall, and ask for continued accommodations for practices that face myriad new requirements in the coming months and years.

ACCC Voices Part B Demo Concerns on Capitol Hill & at CMS

By Amanda Patton, ACCC, Communications

ACCC-PartB-Demo-Meeting-Capitol Hill-crop2With the Medicare Part B Drug Payment Model comment deadline fast approaching (Monday, May 9 at 5:00 pm EDT), ACCC continued its push to educate policymakers on the detrimental impact this ill-conceived proposal will have on community cancer care, providers, and patients.

This morning ACCC President Jennie R. Crews, MD, MMM, FACP;  ACCC Past President Ernest Anderson Jr., MS, RPh, FASHP; and Leah Ralph, Director of Health Policy, ACCC; together with representatives from the Hematology/Oncology Pharmacy Association (HOPA) and the Oncology Nursing Society (ONS), traveled to Capitol Hill to meet with Senate Finance Committee staff and discuss concerns about the Part B proposal’s impact on cancer care. During the meeting, ACCC shared information from a data analysis that reveals the significant financial impact the proposal would have on providers and patients.

In a meeting with CMS Center for Medicare and Medicaid Innovation (CMMI) staff on Monday afternoon, ACCC leadership, along with representatives from HOPA, and ONS—reflected the voice of multidisciplinary cancer care providers.  ACCC shared results from the Part B proposal data analysis and reiterated ACCC’s strong concerns that are reflected in our comment letter to the agency.  Read our comment letter.

Stay tuned for advocacy updates from ACCC.

 

New SGR Fix Proposed—Are We There Yet?

capitol_building_washington_dc_wallpaper_2-normalBy Matt Farber, MA, Director, Provider Economics and Public Policy, ACCC

As most of you know, we are currently in the midst of a short-term, three-month Sustainable Growth Rate (SGR) patch that was passed by Congress  to avert a roughly 24% physician pay cut, which would have gone into effect on Jan. 1, 2014. This short-term fix was passed in order to give Congress more time to work out the differences between three proposed plans to permanently fix the SGR formula. On Thursday, February 6, Congress unveiled a  bipartisan, bicameral bill in the hopes of achieving passage before the current  “patch” expires. Here are some of the pertinent details:

  • 0.5% increase in payments each year for a 5-year span
  • Consolidation of current quality reporting mechanisms (PQRS, VBM, Meaningful Use) into one program that will reward physicians who meet certain performance standards
  • Rewards of up to a 5% bonus payment to physicians who receive a certain portion of revenue from alternative payment models (such as medical homes, ACOs, etc.)
  • Quality and utilization data to be posted to the Physician Compare website.

This newest effort is certainly a step in the right direction.  While ACCC would like to see larger annual increases, we are pleased that positive updates were included in the final bill. The biggest hurdle to passage remains the price tag—which is now estimated to be roughly $120 to $140 billion over 10 years. And, legislators have yet to spell out how Congress will pay for this fix.

ACCC will closely monitor this effort, and also work with elected officials as offsets begin to be discussed.  If you have any questions, please contact mfarber@accc-cancer.org or sabbott@accc-cancer.org.