Read the latest ASCP policy news from Washington, DC.
Pathologists' 2017 MIPS Final Score and Performance Feedback Now Available
Pathologists who participated in the Merit-based Incentive Payment System (MIPS) in 2017 can now access their MIPS final score and performance feedback on the Quality Payment Program website. The final score pathologists received in 2017 will result in a positive, negative, or neutral payment adjustment on covered professional services under the Medicare Physician Fee Schedule in 2019.
If pathologists are concerned that there is an error in their 2019 MIPS payment adjustment calculation, they can request a targeted review with the Centers for Medicare & Medicaid Services (CMS) until Oct. 1, 2018. CMS has developed resources to help clinicians learn more about requesting a targeted review: the Targeted Review of the 2019 Merit-based Incentive Payment System Payment Adjustment Fact Sheet and the Targeted Review of 2019 MIPS Payment Adjustment User Guide. Additionally, CMS plans to host a series of webinars on MIPS, including a session titled "Performance Feedback and Targeted Review Office Hours." You can view the full offering of CMS webinars and register for those of interest here.
If you are eligible to participate in MIPS this year and are looking for a national quality and benchmarking tool, there is still time to take advantage of ASCP’s National Pathology Quality Registry (NPQR). To learn more, click here.
CMS Releases Medicare Outpatient Proposed Rule
CMS proposed notable price increases for pathology, laboratory and blood product/services
On July 25, the Centers for Medicare & Medicaid Services (CMS) published in the Federal Register a Notice of Proposed Rulemaking (NPRM) to update Medicare payment rates and policies under the hospital outpatient prospective payment system (OPPS) and the ambulatory surgical center (ASC) payment system for calendar year (CY) 2019. Comments are due to CMS on Sept. 24.
Payment rates for many pathology, laboratory and blood products and services will experience notable gains in their payment rates. Almost every Ambulatory Payment Classification (APCs) (APCs are payment rates developed around the average cost of a collection of similarly resource/cost intensive services) payment rate affecting pathology, laboratory and blood products and services saw increases above the two-percent average for all OPPS APC rates. The APC for Level 1 pathology services, APC 5671, would increase 15 percent to $51.41 in 2019. Level 2 pathology services, APC 5672, would increase to $144.65 from $129.17, a 12-percent increase. APC 5673, Level 3 pathology service, would rise to $271.73, a 26-percent increase. Level 4 pathology services, APC 5674, would be reduced slightly (2 percent) to $532.66. While the specific services included in each APC vary year by year, it appears that many of the individual services in each APC has held relatively constant, meaning that variation in these APC “baskets” does not explain the price increases.
In addition to the pathology APCs, there is a family of APCs described as “minor procedures.” These APCs cover a number of medical services and include several pathology, laboratory and blood related services. For example, APC 57310, Level 1 minor procedures, includes CPT codes 88300, surgical pathology gross examination, and 86580 TB intradermal test. Services within this APC would be priced at $17.35, up 18 percent. APC 57320, Level 2 minor procedures, includes services like CPT 88302, tissue examination, Level II; CPT 88108, cytopathology concentrate tech; CPT 88321, microslide consultation; 88313, special stains; and CPT 86900, blood typing serological. This APC’s price would increase to $33.49 from $30.84, a 9-percent increase. APC 5734, Level 4 minor procedures, serves few laboratory procedures, but it does include CPT 86900, Blood typing serological abo. This APC would be priced at $108.93, up 11 percent.
Blood product also saw mixed results in pricing. APC 5241, Level 1 Blood Product Services, increased to $383.39, a 2-percent increase. APC 5242, Level 2 Blood Product Services, remained essentially flat at $1,222.97. APC 5243, Level 3 Blood Product Services, increased to 5.7 percent to $3,912.23. Meanwhile, Level 4 Blood Product Services, APC 5244, took a significant hit with its payment rate reduced to $25,645.86, a 16–percent cut.
Also included among the OPPS NPRM’s policy proposals is one to include a number of new CPT Proprietary Laboratory Analyses codes, codes 0045U-0061U, most of which would be paid under the Clinical Laboratory Fee Schedule once their prices have been finalized by CMS. In addition, one of the policy proposals CMS outlined in the NPRM would cap OPPS payment at the Physician Fee Schedule (PFS)-equivalent rate. The proposal is intended to help control the volume of “unnecessary services” that may be incentivized by payment differentials.
CMS noted in this rule, as it did in the PFS Proposed Rule (See ASCP e-Policy Special Edition here), that it has launched its new Meaningful Measures Initiative. This initiative is one component of CMS’s agency-wide Patients Over Paperwork Initiative, which is intended to evaluate and streamline regulations with a goal to reduce unnecessary cost and burden, increase efficiencies and improve beneficiary. The initiative aims to identify the highest priority areas for quality measurement and quality improvement to assess the quality of care issues that are most vital to advancing physician work to improve patient outcomes.
Lastly, the Agency plans to continue its 2.0 percentage point reduction in payments for hospitals failing to hospital outpatient quality reporting requirements.
ASCP Advocacy Prevents Closure of National Guidelines Clearinghouse
ASCP is pleased to report that its advocacy in support of the National Guidelines Clearinghouse (NGC) has paid off. ASCP, in collaboration with 22 other healthcare organizations, had urged the Secretary of the U.S. Department of Health and Human Services (HHS) not to close the NGC. The Agency for Healthcare Research and Quality (AHRQ) announced on July 16, that “AHRQ's decision to close the NGC has elicited significant feedback from the healthcare field, and the Agency appreciates the passionate support that users have expressed.”
In a joint letter, ASCP and others wrote that “to suddenly end support for an established and trusted information site necessary for the execution of evidence-based care in both Health IT and clinical practice” would have negative effects for public health, clinical care, and evidence-based medicine. AHRQ is exploring options to support the NGC in the future and will continue to do so even while the site remains offline.” More detail can be found here. ASCP will update our members as more information becomes available, as we are hopeful the resources offered by the NGC will continue in some form.
CMS Dedicates New Web Page to MAQI Demonstration
The Centers for Medicare & Medicaid Services (CMS) recently created a web page dedicated to the Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) demonstration. The purpose of the demonstration is to test whether exempting MIPS-eligible clinicians with adequate risk contracts with Medicare Advantage plans from MIPS reporting requirements will increase or maintain participation in payment agreements. According to CMS, the demonstration will test whether:
- There is an increase in clinician participation in payment arrangements with Medicare Advantage Organizations (MAOs) that meet the criteria of Qualifying Payment Arrangements
- Participating in Qualifying Payment Arrangements and Advanced APMs to the degree required to be eligible for the Demonstration Waiver incentivizes providers to transform their care delivery (assessed by interviews with participating clinicians)
- Whether there is a change in utilization patterns among participants in the Demonstration, and if there are changes in utilization, how those changes affect Medicare Advantage plan bids.
ASCP will provide feedback to CMS on how this demonstration could impact pathologists who contract with Medicare Advantage plans in our comment letter on the Physician Fee Schedule and the Quality Payment Program due on Sept. 10.
For more information regarding ASCP's advocacy initiatives and policy positions, please contact ASCP's Center for Public Policy at (202-408-1110).
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