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Monday, October 31, 2016

Comprehensive Primary Care Plus program reopening to practices

Practices that missed the application deadline for the Comprehensive Primary Care Plus (CPC+) program will have another opportunity to apply next year.

The Centers for Medicare & Medicaid Services (CMS) recently announced it was reopening CPC+ applications for both payers and practices. Delays in the initial payer application process this summer shrunk the two-month practice application window by two weeks. Many practices felt this was not sufficient time to evaluate the program and determine if the added payment associated with CPC+ would support the amount of work necessary to comply with the program. 

In addition, at that time only one region in the original Comprehensive Primary Care initiative had achieved shared savings, which led some to believe it was not a successful program. On Oct. 17, CMS announced that four of the seven participating regions experienced net savings for 2015, the program’s second performance year.

The CPC+ program is one of the payment models recognized as an Advanced Alternative Payment Model (APM) in the final rule of the Quality Payment Program (QPP), part of the Medicare Access and CHIP Reauthorization Act. Participation in an Advanced APM offers physicians the opportunity to receive a 5 percent bonus payment.

CMS has not yet provided additional details on next year’s reopening of the CPC+ application process. In the meantime, you can learn more about the CPC+ application requirements by reviewing the original Request for Applications.

Kristen A. Stine, MSOD, Practice Transformation Strategist at the American Academy of Family Physicians

Friday, October 21, 2016

Some tips on MIPS included in the final MACRA rule

By now, you may have seen that the Centers for Medicare & Medicaid Services (CMS) has released a final rule that implements the Medicare Quality Payment Program (QPP) called for in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Most of this regulation is final and effective Jan. 1, but CMS seeks comments on some sections.

Meanwhile, here are some highlights for the Merit-based Incentive Payment System (MIPS) portion of the rule:

•    Eligible clinicians only need to score three points and report as little as one measure to avoid a negative payment adjustment in 2019. Eligible clinicians who achieve a final score of 70 or higher will be eligible for the exceptional performance adjustment, funded from a pool of $500 million.
•    Eligible clinicians only need to report for a minimum of 90 consecutive days in 2017 to be potentially eligible for a small upward payment adjustment in 2019, which means you can start reporting as late as Oct. 2, 2017.
•    CMS is decreasing the number of measures eligible clinicians must report.
•    CMS estimates that more than 90 percent of eligible clinicians will receive a positive or neutral payment adjustment in 2019.

Although CMS is still not offering small practices a “virtual group” option under MIPS, there was good news for these physicians. For instance, CMS is excluding more small practices from being subject to MIPS by raising the “low-volume threshold” for exclusion to be $30,000 or less in Medicare Part B allowed charges and 100 or fewer Medicare patients. CMS also estimates that at least 80 percent of solo practices and groups with nine or fewer clinicians will receive either a positive or no MIPS payment adjustment in 2019.

To accompany the final rule and provide more information, CMS also launched a new QPP website and issued an executive summary, press release, blog post from Acting CMS Administrator Andy Slavitt, and fact sheet about the regulation. A family medicine perspective on the final rule is also available.

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

Tuesday, October 11, 2016

New limited English proficiency rule to start Oct. 17

Sometimes, “getting paid” means implementing regulations as cheaply as possible without running afoul of the law. Such is the case with a federal rule that goes into effect next week.

Beginning Oct. 17, the U.S. Department of Health and Human Services (HHS) will require most physician practices to notify patients with limited English proficiency (LEP) of their freedom from discrimination and of the availability of language assistance services. This rule applies to all health programs or activities that receive funding from or are administered by HHS and the health insurance marketplaces as well as all plans offered by issuers that participate in those marketplaces. For instance, if you receive Medicaid payments or a “meaningful use” incentive payment, this rule applies to you. However, if your practice’s only source of federal funds is through Medicare Part B, then this rule does not apply to you.

To comply with the rule, your practice must ensure “meaningful access” for those with LEP by adhering to the following requirements:

•    You must post a notice of nondiscrimination in English and may combine the content of the notice with other notices required under other federal laws.
•    You must post taglines written in the top 15 languages in the state where your practice does business indicating that language assistance is available. HHS has determined the top 15 languages for each state. Ideally, the language of the tagline should be in the language to which it refers; HHS has translated resources on its website.

You must post the notices in a sufficiently prominent and noticeable place in your office, and the rule requires that you post the language assistance taglines on all “significant publications or communications.” This means items that would result in substantial consequences if the patient did not understand (e.g., notice of a treatment plan or a termination of coverage). If the publication or communication is electronic, it must have a link to the notice of nondiscrimination and 15 taglines on the bottom. If it is paper, the publication must have the statement of nondiscrimination and taglines, unless it is something small, like a postcard. In those cases, it only needs the statement of nondiscrimination and the tagline in the top two languages. The notice of nondiscrimination and top 15 taglines should also be at the bottom of your website.

If you have not already done so, now would be a good time to develop a plan to address the needs of patients with LEP. Ideally, the plan should include all languages frequently used in the practice, even if they are not included in the top 15 languages in your state. You may also consider signing up with a language assistance call center to help with the translation of documents as well as telephonic or in-person interpretation when needed. For example, some states’ Medicaid programs regard medical interpretation as a covered service and contract with a vendor to provide it. Your local hospital may also have interpreter resources. Finally, you should consider having commonly used documents translated for frequently used languages.

Enforcement of the new rule will fall to HHS’s Office of Civil Rights, which has indicated that it will use a flexible, context-specific analysis to determine any violations on a case-by-case basis. For additional information, check out the HHS summary and fact sheets and training materials .

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

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