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Thursday, April 27, 2017

Are you participating in MIPS this year? Watch your mailbox

The Centers for Medicare & Medicaid Services (CMS) has begun mailing letters alerting physicians and other health care professionals of their 2017 participation status for the Merit-based Incentive Payment System (MIPS), one of the two reimbursement tracks under the Medicare Access and CHIP Reauthorization Act (MACRA). Practices will receive letters from their local Medicare Administrative Contractor (MAC) through the end of May. The mailings will include three documents: a general information letter, participation information, and list of frequently asked questions.

The letters inform physicians as to whether the group and the individuals within the group are exempt from the MIPS reporting requirements based on their clinician type in 2017 or if they fall below the low-volume threshold. Eligible clinician types include: MD, DO, NP, PA, CNS, and CRNA. Clinicians are considered below the low-volume threshold if during the determination timeframe they billed less than $30,000 in Medicare allowed charges or provided care to fewer than 100 Medicare patients. CMS uses both historical claims data and data from the performance period to make this determination. The letters do not contain information on a clinician’s Advanced Alternative Payment Model (AAPM) status or hospital-based determinations.

Letters are distributed at the practice level, but will contain information on each individual associated with the tax identification number (TIN). If a practice has decided to report as a group, all clinicians within the TIN will be included in the reporting, even if a clinician falls below the threshold as an individual. Practices should review the letters and determine if they will report as individuals or as a group. Clinicians practicing in multiple TINs will need to verify their participation status with each practice.

Participation in MIPS requires clinicians and groups to report data in four performance categories in 2017 in order to avoid a negative payment adjustment in 2019.

– Erin Solis, Regulatory Compliance Strategist at the American Academy of Family Physicians

Thursday, April 6, 2017

Family physician compensation stayed level in 2016

The average annual compensation for family physicians remained stable last year as a majority expressed contentment with their pay and the state of medicine.

The Medscape Physician Compensation Report 2017 shows that family physicians responding to the survey received an average of $209,000 in total compensation in 2016, up almost 1 percent from the previous year but remaining second to the last among all specialties. The average compensation for all physicians included in the survey rose more than 5 percent to $294,000, with the highest average compensation achieved once again by orthopedists at $489,000. The lowest-paid specialty was pediatrics with an average of $202,000, which represented a decrease in compensation.

When broken down by state, data showed that the three top-earning states for physicians were North Dakota ($361,000 average), Alaska ($359,000), and South Dakota ($354,000). Researchers attributed this at least partly to government efforts to bring more physicians to rural and economically disadvantaged areas.

Fifty-three percent of family physicians said they felt their compensation amount was fair, about even with the 54 percent of all survey respondents who said the same. By comparison, 52 percent of family physicians believed they were fairly compensated in 2015. Emergency medicine physicians (at 68 percent) felt the most satisfaction with their compensation in the new survey, while nephrologists (at 41 percent) were the least satisfied.

Among family physicians, 77 percent said they would choose medicine as a career if they had the choice again, in line with the overall average. But family physicians were second from the last (at 67 percent) when asked if they would choose the same specialty. Internists were last at 64 percent.

Although the survey did not disclose physician employment trends as it has in past years, it did note that self-employed physicians, on average, tend to make more than their employed colleagues ($343,000 vs. $269,000). The difference varies widely between specialties, with self-employed primary care physicians earning $223,000 and employed primary care physicians earning $214,000, a 4-percent difference.

The gender pay gap continued to shrink for primary care physicians, albeit slowly. Male physicians in primary care reported earning 16 percent more than female physicians, down from 17 percent the previous year. The gap actually widened among other specialists, where male physicians made 37 percent more then female physicians, a 4 percent increase over the previous year. Researchers said this may be because of fewer female physicians participating in some high-paying specialties.

Gender-based pay disparities are smallest at 18 percent for physicians younger than 35 years old; the pay difference is 35 percent or more for older age groups.

The pool of physicians operating in a cash-only or “concierge” practice actually diminished slightly, with 9 percent of respondents saying they belonged to those types of practices. Ten percent reported operating those types of practices in 2015.

Time ticking for MIPS registration

If your physician group intends to use the Centers for Medicare & Medicaid Services (CMS) Web Interface to report to the Merit-Based Incentive Payment System (MIPS) or the Consumer Assessment of Health Providers and Systems (CAHPS) you have until June 30 to register. You can use the Quality Payment Program (QPP) website to register. No registration is required if you are reporting as an individual or if your group is using any other reporting method.

Only groups of 25 or more clinicians can report using the CMS Web Interface. However, groups of two or more clinicians may administer CAHPS, which is optional in MIPS. Group participants in a Shared Savings Program accountable care organization do not need to register.

CMS has automatically registered groups for the CMS Web Interface if they previously registered as a group under the Physician Quality Reporting System (PQRS). If you need to review or remove your registration, you can do so through the QPP website.

To register, a member of the group must have a valid Enterprise Identity Management (EIDM) account with the Physician Value-Physician Quality Reporting System (PV-PQRS) role. If you are unsure if someone in your group has this role or need to reactivate your account, you can contact the QPP desk at 866-288-8292 or qpp@cms.hhs.gov. CMS has created guides for obtaining the PV-PQRS role or creating a new EIDM account. A CMS Web Interface Registration Guide, a CMS Web Interface fact sheet, and a CAHPS for MIPS fact sheet are also available. CMS will be hosting educational webinars on group reporting and registration in the future.

The QPP was created under the Medicare Access and CHIP Reauthorization Act (MACRA) and adjusts Medicare payments based on the quality of care provided by physicians instead of the volume of services. The first performance period for the QPP began on Jan. 1. More information is available on the American Academy of Family Physicians MACRA ready page.

– Erin Solis, Regulatory Compliance Strategist at the American Academy of Family Physicians

Tuesday, April 4, 2017

The latest Open Payments data is ready for review

Every year, pharmaceutical and medical device manufacturers are required to given the Centers for Medicare & Medicaid Services (CMS) information about the payments or other transfers of value they make to physicians and teaching hospitals. CMS then posts this information on its Open Payments website for the public to see.

Manufacturers are currently submitting data to the Open Payments System on payments or transfers of value made during 2016. Beginning this month, physicians and teaching hospitals have until May 15 to review and dispute records attributed to them. See the Open Payments Registration webpage for more information.

CMS will hold a conference call from 1:30 p.m. to 3 p.m. on April 13 to help physicians and their staffs better understand the Open Payments program and how to review and dispute data submitted about them. CMS will publish the 2016 payment data and updates to the 2013, 2014, and 2015 data on June 30.

To register or for more information on the call, you can visit MLN Connects Event Registration or refer to the call detail page.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Tuesday, March 28, 2017

HHS warns of spoofing scam involving its fraud hotline

The U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) is warning that its fraud hotline telephone number is itself being used as part of a telephone spoofing scam. These scammers represent themselves as HHS OIG employees, even tricking caller ID to make it seem as if the call is coming from the HHS OIG Hotline, 1-800-HHS-TIPS (1-800-447-8477). They then try to obtain or verify the victim’s personal information, which can then be used to steal money or commit other fraud. HHS OIG is investigating and trying to shut the scam down.

In the meantime, HHS OIG stresses that it does not make outgoing phone calls using the HHS OIG Hotline telephone number, and that you should not answer calls from 1-800-447-8477. It is still safe to call into the HHS OIG Hotline to report suspected fraud and abuse. You can also use the HHS OIG Hotline to report if you believe you may have been a victim of the spoofing scam. Alternatively, you can email your information to spoof@oig.hhs.gov or file a complaint with the Federal Trade Commission at 1-877-FTC-HELP (1-877-382-4357).

More information is available on the OIG Consumer Alerts webpage.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Tuesday, March 14, 2017

Act now to get prebooking benefits for next influenza season

The 2016-2017 influenza season is winding down, and hopefully you have used up all your influenza vaccine supply. Right?

As a former office manager, I realize that answer is probably no, and you actually have a lot of leftovers. An essential part of running a medical practice is using your electronic health record or billing system to find the correct number. Determining the amount of flu vaccines you billed over the past two or three flu seasons should help you estimate the number you should order for the 2017-2018 season. Be sure to take into account if your patient panel has grown or decreased. Not only will you be better prepared for the next season but also you can take advantage now of the prebooking options offered by various vaccine manufacturers and distributors.

Prebooking is when you turn in your vaccine order for the upcoming flu season order in advance, typically by the end of March. Admittedly, it is difficult to manage this number effectively because you are doing it an average of five to six months ahead of when you will need the vaccine in your clinic. The manufacturers and distributors have programs available that can help you manage your inventory as well as keep your costs down. Some prebooking programs have matrixes to help determine the number of vaccines to order, staggered shipping, order forgiveness, and volume discounts. These factors can lead to diminished costs, which, of course, can lead to greater profit margins.

You are encouraged to contact the major manufacturers and distributors directly to see what their individual prebooking programs offer. These will vary based on your practice size, patient panels, and volume discounts. Here is contact information for some of the manufacturers:

• Sanofi Pasteur (www.VaccineShoppe.com) 800-822-2463

• GlaxoSmithKline (www.gskdirect.com) 866-475-8222

• Seqirus  (www.flu.seqirus.com) 855-358-8966

• Protein Sciences (www.flublok.com) 203-686-0800

– Barbie Hays, CPC, CPMA, CPC-I, CEMC, Coding and Compliance Strategist for the American Academy of Family Physicians

Tuesday, February 21, 2017

CMS awards millions to help small practices succeed in the QPP

The Centers for Medicare & Medicaid Services (CMS) is rolling out a new effort to give clinicians in solo and small group practices on-the-ground training and education about the Quality Payment Program (QPP). CMS has announced $20 million in grants to 11 organizations to provide the services for the first year of a five-year program. Working through the Medicare Access and CHIP Reauthorization Act (MACRA), CMS plans to invest up to an additional $80 million over the remaining four years.

CMS awarded contracts to the following organizations:

• Altarum

• Georgia Medical Care Foundation (GMCF)

• HealthCentric

• Health Services Advisory Group (HSAG)

• IPRO

• Network for Regional Healthcare Improvement (NRHI)

• QSource

• Qualis

• Quality Insights (West Virginia Medical Institute)

• Telligen

• TMF Health Quality Institute

These groups will provide hands-on training to help thousands of small practices, especially those in historically under-resourced areas, including those that are rural, have a shortage of health professionals, or are medically underserved. For example, clinicians will receive help choosing and reporting on quality measures, as well as guidance with all aspects of the program, including supporting change management and strategic planning and assessing and optimizing health information technology. The training and education resources will be available immediately, nationwide, and will be provided at no cost to eligible clinicians and practices.

To find out if your practice is eligible for this assistance, you can call 1-866-288-8292 from 8 a.m. to 8 p.m. (EST) or email qpp@cms.hhs.gov.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, February 16, 2017

Executive orders and family medicine

Amid the furor surrounding other executive orders recently signed by President Donald Trump, family physicians may find one on which they can agree.

On Jan. 30, the administration issued an executive order titled, “Reducing Regulation and Controlling Regulatory Costs.” The order establishes a framework designed to reduce the cost of compliance with federal regulations. First, it provides that federal agencies, when proposing a new regulation, must “identify at least two existing regulations to be repealed.” Second, it requires that the incremental cost of any new regulation be “no greater than zero.”

The stated intention of the executive order is to decrease the cost of running a business (such as a family medicine practice), to the extent that regulations from federal agencies contribute to such costs.  The order says that all new regulations must be cost-neutral and that the net impact (new regulation minus the two repealed regulations) cannot increase "incremental costs" on the regulated community. Finally, exceptions will be considered on a case-by-case basis. 

The implementation of the order is left to the Office of Management and Budget (OMB). On Feb. 2, OMB issued to all government agencies a memo containing interim guidance and frequently asked questions on how to implement this order.  This memo clarifies that:

•    The order applies to "significant" regulations. "Significant" is not defined in the guidance, but under a 1993 Executive Order still in effect, a "significant" rule is defined as any that imposes an annual economic cost of $100 million or more.  
•    Government agencies intending to issue a “significant regulatory action” on or before Sep. 30, must first “identify two existing regulatory actions the agency plans to eliminate or propose for elimination” before the new regulation is issued.
•    Agencies must “fully offset total incremental cost” of the new regulation as of Sep. 30.
•    The costs of regulations are “measured as the opportunity cost to society,” defined as "the net benefit [a] resource would have provided in the absence of the requirement."
•    Waivers exist for regulations that address health, safety or financial emergencies. 

Future rules governing Medicare physician payment (such as those implementing the Medicare Access and CHIP Reauthorization Act of 2015, or MACRA) could be shaped by this order. Stay tuned!

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Wednesday, February 8, 2017

Meaningful use deadlines extended to March 13

It is the season for Medicare program deadline extensions. If you are in the process of reporting your 2016 data for the Medicare Electronic Health Record (EHR) Incentive Program, also known as meaningful use, the deadline has just been extended from Feb. 28 to 11:59 pm (PT) on March 13. The Centers for Medicare & Medicaid Services (CMS) said this extension applies to those eligible professionals looking to avoid a negative payment adjustment on Medicare reimbursements in 2018.  Those participating in the Medicaid EHR Incentive Program should refer to the attestation deadlines in their particular state.  

However, there is still one critical Feb. 28 deadline remaining. If CMS has notified you that your practice failed to successfully demonstrate meaningful use for the 2015 performance year, meaning you are scheduled to receive a negative payment adjustment on all Medicare reimbursements in the associated 2017 payment year, you still must complete and submit a application to request reconsideration by the end of the month. Likewise, if you applied for a hardship exception tied to challenges in the 2015 performance year and your application was denied, you still need to complete a request for reconsideration by Feb. 28 or face negative payment adjustments this year.

The application for reconsideration and instructions related to the application are available on the CMS website for EHR Incentive programs, payment adjustments, and hardships.  For questions about the Reconsideration Application, email pareconsideration@provider-resources.com.

For questions about the Registration and Attestation System, contact the EHR Information Center at 1-888-734-6433 (option 1), which is open Monday through Friday from 6:30 am to 5:30 pm ET.

– Theresa Wilkes, Medical Informatics Strategist for AAFP

Friday, February 3, 2017

Deadline extended for certain PQRS reporting

If you are reporting to the Physician Quality Reporting System (PQRS) using the Electronic Health Record (EHR) method, you now have a little more time to submit your data. The Centers for Medicare & Medicaid Services (CMS) recently announced that it was extending the Feb. 28 deadline for PQRS submission through the EHR or qualified clinical data registry (QCDR) mechanisms.

Eligible professionals (EPs) and groups have until March 31 to submit their 2016 quality reporting document architecture (QRDA) I or III files for the EHR Direct, EHR Data Submission Vendor (DSV), and QCDR reporting mechanisms. Qualified registries and QCDRs that use XML files also have until March 31 to submit. Vendors may have their own individual deadlines that may be earlier. EPs should work directly with their vendors to ensure their data is submitted before the deadline.

EPs who fail to satisfactorily report to PQRS for 2016 will receive the maximum negative payment adjustment in 2018. EPs failing to report will also face the maximum negative payment adjustment for their group size under the Value-Based Payment Modifier Program (VBPM). Payment adjustments for the PQRS and VBPM are separate from those for the Medicare Electronic Health Record Incentive Program (a.k.a “meaningful use”). EPs have until March 13 to submit their meaningful use data. EPs can submit CQMs using the PQRS EHR reporting method or QCDR QRDA III files to fulfill the CQM requirements for both meaningful use and PQRS. EPs can contact the QualityNet Help Desk for questions about PQRS and the EHR Information Center Help Desk (1-888-734-6433, option 1) for questions relating to meaningful use.

The final year for which EPs are required to submit data for PQRS, VBPM, and meaningful use is 2016. The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 consolidates these programs into the Quality Payment Program (QPP). The first performance period for the QPP began on Jan. 1. Physicians can learn more about the QPP on the AAFP website or in the latest issue of FPM.

– Erin Solis, Regulatory Compliance Strategist at the American Academy of Family Physicians

Wednesday, January 25, 2017

MIPS help offered for practices in rural and underserved areas

The Centers for Medicare & Medicaid Services (CMS) is inviting small practices that work in rural and medically underserved areas to join a webinar on Wednesday, Feb. 1, at 1:00 p.m. (Eastern Time) to learn more about participation in the Merit-based Incentive Payment System (MIPS) track of the Quality Payment Program.

During the webinar, CMS will provide information about eligibility, how to participate in MIPS in 2017, methods for submitting data to CMS, performance categories, how practices are scored, and other resources for these types of practices.

Participants will also have the opportunity to ask questions during a Q&A session.

Registration is available online: https://engage.vevent.com/rt/cms/index.jsp?seid=682

Space for this webinar is limited, so you are encouraged to register as soon as possible to secure your spot. After you register, you will receive an email message with a webinar link.

For more information on MIPS and the Quality Payment Plan in general, read this article in the latest issue of FPM.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Tuesday, January 10, 2017

Physicians, groups to get breather on PQRS penalties

It seems the most recent round of updates to ICD-10 coding has caused enough concerns at the Centers for Medicare & Medicaid Services (CMS) that the agency is temporarily eliminating payment penalties based on those changes.

The CMS this week announced that the changes are expected to affect its ability to process data for certain quality measures within the Physician Quality Reporting System (PQRS). As a result, individuals and groups that fail to satisfactorily report 2016 PQRS data solely because of the 2016 coding changes will not face 2017 or 2018 PQRS negative payment adjustments. Those who fail to satisfactorily report for reasons other than coding, however, are still at risk.

The changes affected a variety of measures, but the majority related to diabetes, pregnancy, cardiovascular, oncology, mental health, and eye disease diagnosis. This includes the diabetes, cataracts, oncology, cardiovascular prevention, and diabetic retinopathy measures groups.

Even if you believe the changes to ICD-10 affected your ability to meet the reporting requirements satisfactorily, CMS still expects you to report to PQRS. Once the 2016 reporting period ends, CMS plans to conduct an analysis to review and determine which submissions were negatively affected by the ICD-10 changes. Individuals and groups that feel they have received a negative payment adjustment as a result of the ICD-10 changes will also be able to file an informal review.

CMS advises that eligible professionals (EPs) should use the codes in the measure specification sheets for their respective reporting mechanism. Qualified registry, electronic health record, and qualified clinical data registry vendors should continue to calculate the measures according to their particular measure specification sheet.

EPs and vendors can contact the QualityNet Help Desk for assistance. CMS has also published frequently asked questions.

--Erin Solis, Regulatory Compliance Strategist at the American Academy of Family Physicians

Friday, January 6, 2017

Medicare’s Quality Payment Program is coming; two opportunities to get ready

The new year has begun, which means the Medicare’s Quality Payment Program (QPP) becomes even more important as what you do (or don’t do) in 2017 may affect your Medicare payments in 2019. The Centers for Medicare & Medicaid Services (CMS) is offering two opportunities this month to get a leg up now on the new QPP.

First, CMS is conducting a Clinical Practice Improvement Activities Study and will accept applications for the study through Jan. 31. CMS says it is leading this study to examine clinical workflows and data collection methods using different submission systems and to understand the challenges facing physicians and other clinicians when collecting and reporting quality data. The agency says it will use this information to recommend ways to eliminate burdens, improve collection and reporting of quality data, and enhance clinical care.

Study participants must meet the following requirements between January and December of this year:

•    Complete at least three survey questionnaires.
•    Participate in at least three focus groups.
•    Submit at least three clinician quality performance measures to CMS.

If you or your physicians group is eligible for the Merit-based Incentive Payment System (MIPS) and successfully participates in the study, CMS will award you full credit for the Improvement Activities performance category of MIPS. Participants will also get direct feedback from other study participants and CMS during the study on how to reduce problems with data collection and submission.

For more information and to apply to participate in the study, please visit the CMS website. You should submit your completed applications to CMSCPIAStudy@ketchum.com by Jan. 31.

CMS will also host a call titled “Medicare Quality Programs: Transitioning from PQRS to MIPS” on Tuesday, Jan. 24, from 2:00 p.m. to 3:30 p.m. (EST). During this call, you can find out how to complete the final reporting period for the legacy Medicare quality reporting programs and transition to MIPS.

To register, please visit MLN Connects Event Registration. CMS is evaluating this call for continuing medical education credit. Please refer to the call detail page for more information.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Tuesday, December 20, 2016

2015 quality data now available on Physician Compare website

The Centers for Medicare & Medicaid Services (CMS) this week published quality data for 2015 on the Physician Compare website. The data included selected 2015 Physician Quality Reporting System (PQRS) measures, non-PQRS measures, and Consumer Assessment of Healthcare Providers and Systems (CAHPS) measures for both individual physicians and group practices or accountable care organizations (ACOs).

Depending on how the data was reported, the newest batch of information includes the following data from 2015:
     •    90 individual clinician-level PQRS measures collected through claims and registry, and 16 non-PQRS measures collected through Qualified Clinical Data Registries (QCDRs) for approximately 175,000 individual clinicians;
     •    91 group practice-level PQRS measures collected via the web interface and registry and eight CAHPS measures for approximately 2,500 group practices
     •    19 Shared Savings Program and Pioneer ACO measures for approximately 400 ACOs.

The release does not include any measures reported by electronic health record for 2015 because that information continues to be plagued by data integrity issues.

Since starting the Physician Compare website in 2010, CMS has continued to enhance the site to provide data that is both useful to consumers and assists them to make informed health care decisions. CMS also believes transparency motivates better physician performance.

Each measure is scored using a star-rating system with each star representing 20 percent of the total score (e.g., five stars is 100 percent, four stars is 80 percent, etc.)

This information is important to physicians because it reflects on their reputation and may influence potential patients to either seek out or avoid a practice. The CMS plans to eventually add information collected under the Medicare Access and CHIPS Reauthorization Act (MACRA) such as data for each of the four Merit-based Incentive Payment System categories (quality, cost, improvement activities, advancing care information) and final scores. Advanced Alternative Payment Model data will also be available, similar to ACO data now.  Item-level benchmarking will be incorporated into the star rating system.

CMS will host webinars on Feb. 21 and 23 about recent updates to Physician Compare. Additional information regarding these events, including registration information, will be available soon. If you have any questions about Physician Compare or the 2015 performance scores release, contact the CMS Physician Compare contractor at PhysicianCompare@Westat.com.

– Sandy Pogones, MPA, CPHQ, Senior Strategist for Health Care Quality for the American Academy of Family Physicians

Friday, December 16, 2016

Changes to renewing DEA registration for physicians

Update: After this blog item was originally posted, the DEA announced that it had reversed its decisions to eliminate a second registration renewal notice to prescribing physicians and eliminate the grace period for renewals after Jan. 1. Instead, the DEA said it would retain its current policies and procedures for renewing DEA registration although registrants will now receive the second renewal notification at the email address associated with their registration instead of through the mail.

There are many moving parts to practicing as a family physician and one of those is being able to prescribe needed medications for your patients. That depends on having a valid, current registration with the U.S. Drug Enforcement Administration (DEA).

The DEA recently announced significant changes to its registration renewal process. Effective Jan. 1, the DEA is eliminating the informal grace period that the agency had previously allowed for registrants to renew their registrations. The DEA will send only one renewal notice to each registrant’s “mail to” address approximately 65 days before the expiration date; DEA will provide no other reminders to renew the DEA registration.

The DEA also advises that physicians who fail to file a renewal application by midnight Eastern Standard Time of the expiration date will have their DEA number “retired” and have to apply for a new one. The agency also says after the expiration date physicians won’t be able to renew a DEA registration online and the DEA won’t accept paper renewal applications.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

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