October 24, 2016

By Daniel Spirn, AAN Regulatory Counsel 

CMS' Final MACRA Rule Links Neurologist Payments to Quality and Outcomes, Addresses AAN Concerns

On Friday, October 14, the Centers for Medicare & Medicaid Services (CMS) released its final rule that links Medicare provider payments to quality patient care under the Medicare Access and CHIP Reauthorization Act of 2015, also known as MACRA. The rule represents one of the biggest changes to Medicare in its 50-year history. Earlier this year, we submitted comments to CMS on its proposed rule. Now, in its final version, CMS responded to our concerns with a series of changes to the rule, including an option for neurologists to select their own pace in the first year of this new payment program and modifications that will help ease the burden on smaller practices.

The nearly 2400-page regulation outlines a number of significant changes to Medicare as a result of MACRA. CMS reaffirmed its plan to create a “Quality Payment Program” that replaces old reporting programs with a new, two-track system for Medicare reimbursement-the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs). One of the important changes in the final rule allows neurologists to pick the pace at which they participate in MACRA for the 2017 performance year. Neurologists may choose one of the four options to ensure that you do not receive a payment penalty in 2019 based on your 2017 data: 

  • Full-year reporting: this offers an opportunity to earn a moderate positive payment bonus
  • Partial-year reporting: by submitting 90 days of 2017 data to Medicare, you may earn a neutral or small positive payment bonus
  • Test-option reporting: through the submission of a minimal amount of 2017 data to Medicare, such as one quality measure or one improvement activity, you can avoid a payment penalty
  • APMs: participating in an Advanced Alterative Payment Model (APM)

If you choose not to submit any 2017 data, then you will receive a negative 4 percent payment penalty.

Some other changes will be especially important to small neurology practices. In the final rule, CMS estimates that around 25 percent of neurologists will be excluded from MIPS. One major reason is that eligible clinicians are excluded if they do not exceed the low-volume threshold: those with $30,000 or less in Medicare Part B allowed charges or 100 or fewer Medicare patients as measured at the TIN/NPI level for individual reporting, the TIN level for group reporting.

Additionally, the rule finalizes the 2017 MIPS performance period which begins on January 1 and ends on December 31 for all measures and activities. Performance reporting requirements have been further reduced, and the resource use component of MIPS has been reweighted to zero for 2017. The agency also is finalizing requirements for third party data submission to MIPS with an aim to decrease the burden on individual clinicians. Qualified clinical data registries (QCDRs), like the AAN's  Axon Registry™, will have the ability to act as an intermediary on behalf of a neurologist under MIPS to submit data to CMS across the quality, improvement activities, and advancing care information performance categories.

CMS continues to work on appropriate levels of risk for alternative payment models but did finalize a number of proposals to establish Advanced APMs. CMS states its intention to broaden opportunities for clinicians to participate in Advanced APMs by working to include some existing models as meeting the necessary criteria and working with the CMS Innovation Center to create new models, including those recommended by the Physician-Focused Payment Models Technical Advisory Committee (PTAC).

The AAN has created two condition-based APMs for neurology that will be submitted to the PTAC. The initial APMs focus on two common disease areas, headache and epilepsy, and the AAN plans to develop more condition-based APMs. In the future, these models may qualify under the APM track of MACRA and allow neurologists to negotiate new arrangements with payers. 

Check out AAN resources for additional information on MACRA. The AAN will host a free practice management webinar, “Decoding the 2017 Medicare Fee Schedule and MACRA Rule,” on December 13, 2016, from 12:00 p.m. to 1:00 p.m. ET. We are encouraging members to review CMS' new Quality Payment Program website. CMS offers a fact sheet that provides details and infographics on this new program. Practices also can identify organizations to help them with MACRA.

New Tool Helps Neurologists Prepare for MACRA

Neurologists feeling overwhelmed by the challenges facing their practice as a result of the pending implementation of the Medicare Access and CHIP Reauthorization Act (MACRA) have a new tool to provide assistance. The AAN is partnering with the American College of Physicians (ACP) to make neurologists aware of an opportunity to join a new program known as the “Transforming Clinical Practice Initiative” (TCPi).

Through the TCPi, practices will receive extensive training and support services helping to build the foundation necessary to succeed under MACRA and value-based programs overall. We want to stress that AAN members do not need to be a member of the American College of Physicians to take advantage of this opportunity. 

The ACP is working through a CMS grant-funded program to help practices of any size, and this is a risk-free, no cost program. But there are plenty of benefits for neurologists. TCPi participants will receive support and education on the best practices to collect, improve, and submit data related to demonstrating value; use this data to enhance patient care; learn methods and processes to reduce practice burdens; and improve care coordination. Some programs are filling up, so it pays to look into this soon.

Instead of trying to figure this out on your own or hiring an expensive consultant, you can be a part of this nationwide initiative that provides education, tools, and support to ensure success under the changes coming as a result of MACRA. You can find general information about TCPi. Please email SAN@acponline.org to participate in the initiative. Learn more about MACRA including the top 5 things you can do today to prepare and an opportunity to contact the AAN with your MACRA-related questions.

Connecting with AAN Members Outside of DC

By Mike Amery, Esq., Senior Legislative Counsel, Federal Affairs 

With Congress out of Washington, I left DC to meet up with AAN members in Florida, Pennsylvania, and the AAN Fall Conference in Las Vegas.

The Florida Neurosociety meeting was well attended with more than 100 AAN members participating. I talked to a lot of neurologists about MACRA and what we are doing in DC and was joined for much of the time by former Florida State Neurosociety President Glen R. Finney, MD, who is a member of the AAN's BrainPAC Executive Committee. MACRA was also covered in great detail by AAN Government Relations Committee member James N. Goldenberg, MD, FAAN, who provided a course on the new payment system. I followed this with a Grand Rounds presentation on advocacy and MACRA at Penn State University Medical Center in Hershey, PA.

The Fall Conference was a great event with more than 500 attendees. I spent most of my time raising contributions for BrainPAC and what struck me is the diversity of viewpoints among AAN members. I had the following conversations within five minutes of each other. First, a neurologist and long-time contributor to BrainPAC came up and said, “I can't do as much this year because I'm doing everything I can for Trump.” Then, the very next person I talked to handed me a credit card and said, “I really support  AAN's efforts, but I shouldn't be doing this.  I should be doing more for Hillary.”

Two more weeks. Two more weeks.

Join Us for Free Post-election Webinar
Join AAN Government Relations Committee Chair Nicholas E. Johnson, MD; BrainPAC Executive Committee Chair Lily Jung Henson, MD, MMM, FAAN; and me for a free post-election webinar on Tuesday, Nov. 15. We will run through the top races and discuss the potential impacts on AAN priorities.

Sonal Mehta, MD, a 2016 Palatucci Advocacy Leadership Forum graduate, put his media skills to work in this great interview and description of telestroke care in South Carolina. Apply for the 2017 Palatucci Forum before January 9.

Don't forget to put in your application to attend the 15th annual Neurology on the Hill in Washington, DC, on February 27-28, 2017. The deadline is November 20.