REGULATORY REVIEW


tional suggestion that CMS clearly state that the pre-surgery anesthesia risk assessment and the risk assess- ment for the surgery to be performed were distinct elements, and that the CRNA should not be performing the risk assessment for the procedure itself. CMS took ASCA comments into account and did ultimately final- ize this proposal put forth by ASCA and other industry stakeholders.


Colonoscopy Patient Copay Notification Not Finalized


CMS did not choose to finalize a proposal that would have required physicians to notify Medicare patients that coinsurance may apply if polyps are found and removed during a screen- ing procedure, thereby making it a diagnostic procedure. Although ASCA has been vocal in opposing this loophole that springs surprise coinsurance on patients—including supporting federal legislation such as the Removing Barriers to Colorectal Cancer Screening Act and signing on to a letter by the Amer- ican Cancer Society Cancer Action Network—ASCA and many other orga- nizations do not believe that the proper solution is additional notification bur- den on the treating clinicians.


Evaluation and Management (E/M) Adjusted Values Finally, against the strong opposition of ASCA and many others in the med- ical community, CMS has decided not to apply adjusted values for stand- alone evaluation and management (E/M) visits to E/M visits that occur as part of 10- and 90-day global surgi- cal packages. Many argue that failing to incorporate E/M updates will dis- rupt relative payments between pro- cedures and devalue surgical special- ties that are providing the same E/M services as part of the global packages but not realizing updated payments. The MIPS program, which will enter its fourth performance year in 2020, saw no structural changes. CMS


has been incrementally increasing the weights for the various performance categories and for the overall perfor- mance threshold so that clinicians can be ready when statutory require- ments begin to affect the program in 2022. The performance threshold for the 2020 performance year will be 45 points, and the performance catego- ries will be weighted the exact same as the 2019 performance year: Quality at 45 percent, Cost at 15 percent, Pro- moting Interoperability at 25 percent, and Improvement Activities at 15 per- cent. Clinicians who perform greater than 75 percent of covered services at ASCs are considered ASC-based and are not subject to reporting the Pro- moting Interoperability performance category. Beginning in 2022, the per- formance threshold will be automati- cally set at the mean or median final scores for all MIPS clinicians in the prior year, and the cost and qual-


ity performance categories will be equally weighted at 30 percent each. CMS will move


forward with


development of yet another value- based program within MIPS, a track they are calling MIPS Value Path- ways (MVP). First announced in the proposed rule, the MVP frame- work will seek to align specific mea- sures from each of the performance categories around clinical special- ties. Ideally, according to CMS, this would allow clinicians to report on both fewer measures and measures that are more targeted to their clin- ical line of work. CMS expects to announce details on the MVP frame- work in 2020 with a potential first performance year of 2021.


Kara Newbury is ASCA’s director of Government Affairs and Alex Taira is ASCA’s policy analyst. Write her at knewbury@ ascassociation.org and him at ataira@ ascassociation.org.


CELEBRATING 75 YEARS OF EXCELLENCE IN HEALTHCARE ACCREDITATION


HFAP provides:


• Trusted, recognized programs for ASC accreditation with or without Medicare deemed status.


LEARN MORE: WWW.HFAP.ORG


CONTACT US: 312.920.7383


INFO@HFAP.ORG


• Accreditation for clinical laboratories.


• Certification for Joint Replacement programs and Compounding Pharmaceuticals.


• Responsive, accessible, cost-effective customer support.


ASC FOCUS FEBRUARY 2020 | ascfocus.org


21


Page 1  |  Page 2  |  Page 3  |  Page 4  |  Page 5  |  Page 6  |  Page 7  |  Page 8  |  Page 9  |  Page 10  |  Page 11  |  Page 12  |  Page 13  |  Page 14  |  Page 15  |  Page 16  |  Page 17  |  Page 18  |  Page 19  |  Page 20  |  Page 21  |  Page 22  |  Page 23  |  Page 24  |  Page 25  |  Page 26  |  Page 27  |  Page 28  |  Page 29  |  Page 30