REGULATORY REVIEW
Alternative Payment Models As an alternative to MIPS, physicians also have the option to participate in an Advanced Alternative Payment Model (AAPM). This alternative might appeal to many physicians, because those who do are not required to report perfor- mance data through MIPS and will not be exposed to negative payment adjust- ments. Instead, at least for the first five years of the program (i.e., from 2019 through 2024), Medicare payments to physicians participating in AAPMs will be increased by 5 percent in addition to any gainsharing that may be available under the AAPM. Physicians partici- pating in AAPMs also are eligible for higher annual payment inflation adjust- ments in the early years of the program. To be exempt from MIPS and qual-
ify for AAPM bonuses and updates, pro- viders must participate in a qualifying program and meet certain participation thresholds. Surgeons are likely to have a limited number of AAPM participation opportunities in the early years. Surgeons
practicing in an ASC environment may have even fewer options. In the agency’s proposed rule, CMS identified six quali- fying Advanced APMs. CMS proposed to add three new Advanced APM mod- els in July 2016, but those that are avail- able to surgeons, typically, will require that those surgeons furnish services in the hospital setting. To date, CMS has not proposed an ASC-based Advanced APM. CMS is establishing a process whereby physician groups,
including
specialty societies, can propose quali- fying Advanced APMs, but those pro- grams will not be immediately available as options. In recent comments, ASCA urged CMS to implement a request for proposals process that is flexible enough to address the needs of the wide range of surgical specialties that practice in the ASC environment. Initially, a determination of whether
a physician is adequately participating in an Advanced APM will be made based on Medicare fee-for-service allowed charges and patients. Beginning in 2021, some
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arrangements with commercial payers also may be countable toward determin- ing whether a physician is sufficiently participating in an Advanced APM and is, therefore, exempt from MIPS.
Preparing for MACRA Important deadlines related to the implementation of MACRA are fast approaching since, as stated above, the MIPS data submission that will begin in 2018 will reflect services furnished in 2017. Physicians and facilities can begin
preparing for implementation
now by better familiarizing themselves with MACRA as follows: ■
CMS has produced a series of use- ful webinars explaining the MACRA changes. These programs are available at
https://www.cms.gov/Medicare/ Quality-Initiatives-Patient-Assess- ment-Instruments/Value-Based-Pro- grams/MACRA-MIPS-and-APMs/ Quality-Payment-Program-Events. html. View these webinars to get a more in-depth understanding of these upcoming changes.
Determine whether you have ade- quate technologies and reporting arrangements to capture and report MIPS data.
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Review the list of the MIPS quality measures for your specialty. Physi- cians may already be reporting some or all of these measures as part of their participation in the Physician Quality Reporting System.
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Inspect the proposed Clinical Prac- tice Improvement Activities (CPIA) list to evaluate which of these activi- ties you are currently performing or can begin performing once the per- formance period begins. ASCA is closely monitoring
MACRA implementation and will continue to update its members as additional critical information becomes available.
Sheila Madhani is a director at McDermott+ Consulting in Washington, DC. Write her at
smadhani@mcdermottplus.com
22 ASC FOCUS NOVEMBER/DECEMBER 2016
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