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Review Your MIPS Score Now

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If you participated in the Merit-based Incentive Payment System (MIPS) in 2017, your MIPS final score and performance feedback is now available for review on the Centers for Medicare & Medicaid Services (CMS) Quality Payment Program website. If you believe an error has been made in your 2019 MIPS payment calculation, you can request a targeted review until October 1.

If you have questions about the MIPS performance feedback—what it is and who receives this—go to https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2017-Performance-Feedback-fact-sheet.pdf. If you have questions about your performance feedback or MIPS final score, contact the Quality Payment Program at 866-288-8292 or QPP@cms.hhs.gov.

CMS Posts MIPS Payment Adjustment Fact Sheet

CMS has posted a fact sheet about the 2019 MIPS payment adjustment for clinicians and groups. The facts sheet highlights how the agency assigns final scores to MIPS eligible clinicians and how payment adjustment factors are applied for 2019 based on 2017 MIPS final scores.

The document addresses issues such as MIPS participation, performance evaluation, and payment adjustment applications for individuals versus group. It includes questions and answers to illustrate how payment adjustments are applied based on different ways of participating in the program.

The fact sheet is available at https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2019-MIPS-Payment-Adjustment-fact-sheet.pdf.

CMS Advances Demonstration to Waive MIPS Requirements for Some Clinicians

Last month, CMS advanced its Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) Demonstration, which, when approved and adopted, would waive MIPS requirements for clinicians who participate sufficiently in certain Medicare Advantage (MA) plans that involve risk assumption. The agency is seeking public comment on the information collection burdens associated with the demonstration, which is under consideration for formal approval.

Some MA plans are developing innovative arrangements that resemble Advanced Alternative Payment Models (APMs). However, without this demonstration, physicians are still subject to MIPS, even if they participate extensively in Advanced APM-like arrangements under MA.

According to CMS Administrator Seema Verma, “The MAQI Demonstration aligns with the Agency’s goal of moving to a value-based healthcare system and aims to put Medicare Advantage on a more equal playing field with Fee-for-Service Medicare.” She added that the agency intends to test whether MIPS exemptions provided to clinicians under MAQI will increase participation in MA plans that “are similar to Advanced APMs, and thereby accelerate the transition to a healthcare system that pays for value and outcomes.”

Implications of the QMB Program

Medicare providers may not bill beneficiaries who are enrolled in the Qualified Medicare Beneficiary (QMB) program for Medicare Parts A and B deductibles, co-insurance, or copays. This is prohibited by federal law; however, state Medicaid programs may pay for these costs. To help you identify your patients’ QMB status, CMS has reintroduced QMB information in provider Remittance Advices (RAs) and Medicare Summary Notices (MSNs) for claims processed on or after July 2, 2018. You also can verify QMB enrollment via Medicare eligibility information returned by the HIPAA Eligibility Transaction System (HETS) 270/217 application.

FDA Commissioner Releases Statement about Opioid Abuse and Chronic/End-of-Life Pain

In a statement released late last week, FDA Commissioner Scott Gottlieb, MD, observed, “While we work to ensure appropriate and rational prescribing of opioids, we won’t lose sight of the needs of Americans living with serious chronic pain or coping with pain at the end of life. They too face significant challenges.” He went on to say, “So, as we consider new policy steps to address the opioid addiction crisis, the FDA remains focused on striking the right balance between reducing the rate of new addiction by decreasing exposure to opioids and rationalizing prescribing, while still enabling appropriate access to those patients who have legitimate medical need for these medicines.

Among other highlights from the statement:

  • The FDA is holding a Patient-Focused Drug Development meeting to gather additional viewpoints directly from adult and pediatric patients living with chronic pain and “better understand the challenges or barriers patients face accessing various treatments for pain.”
  • Dr. Gottlieb observed that there are “still too many prescriptions being written for opioids, and too many prescriptions writer for long duration or use that aren’t appropriate for the medical needs for which the opioid is being prescribed. This presents a difficult challenge both for the FDA and for providers.” He stressed that the agency doesn’t want to act in ways that end up “disadvantaging legitimate patients.”
  • The FDA is “aware that there are certain circumstances—such as in the treatment of metastatic cancer pain and the episodic treatment of migraine pain—where the drugs are administered over longer periods.”
  • The agency recently released a revised blueprint of the core content for training that opioid drug manufacturers are required to make available to prescribers. This blueprint includes information on acute and chronic pain management, safe use of opioids or other non-opioid or non-drug treatments, as well as material on addiction medicine and opioid use disorders.
  • For the first time, FDA is “requiring training to be offered on non-opioid alternatives for the treatment of pain” and extending educational material to other health care professions (besides prescribers) who participate in the treatment and monitoring of pain, such as pharmacists and nurses. When it is finalized later this year, the blueprint “will apply to manufacturers of other immediate-release opioid analgesics intended for use in the outpatient setting and extended release and long-acting formulations of these drugs.”
  • The agency is taking new steps to encourage medical professional societies to develop evidence-based guidelines on appropriate prescribing of opioids for different medical indications.
  • The FDA recently launched an innovation challenge to spur development of medical devices, including digital health and diagnostics, that could provide novel solutions to treating pain. The agency also is planning to create a new series of guidance documents “aimed at promoting the development of new drugs targeted to the treatment of various types of pain.”

Read the entire statement at https://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm612779.htm.

CMS Proposes Changes to Payment Rules on DME

Earlier this month, CMS proposed innovative changes to the payment rules for Durable Medical Equipment Prosthetics, Orthotics, and Supplies (DMEPOS) and the End-Stage Renal Disease (ESRD) program. The DME proposals in the proposed rule aim to increase access to items for patients and simplify Medicare’s DMEPOS Competitive Bidding Program (CBP) to drive competition and increase affordability. The rule also includes ESRD proposals, including a proposal to address new renal dialysis drug and biological costs and foster innovations in treatment by incentivizing new therapies for patients on dialysis and a proposal to reduce facility-related documentation burden.

“At CMS, we celebrate innovation in the health care system and encourage new therapies that will help save lives and lower costs for patients,” said CMS Administrator Seema Verma. “Today’s proposals will help secure sustainable access to durable medical equipment and reward dialysis facilities that adopt innovative new therapies.”

The proposed rule takes key steps towards changing Medicare’s DME fee schedule payments and the DMEPOS CBP. CMS sought ways to improve competitive bidding going forward and worked with market experts to leverage opportunities to increase the program’s effectiveness. This rule proposes market-oriented reforms to the DMEPOS CBP. The process for recompeting contracts with suppliers currently in effect under the DMEPOS CBP has not yet been initiated. As a result, we note that the current contracts for the DMEPOS CBP will expire on December 31, 2018. Beginning January 1, 2019, and until new contracts are awarded under the DMEPOS CBP, beneficiaries may receive DMEPOS items from any Medicare enrolled DMEPOS supplier.