By Katie Shepard, Director, Medical Economics

CMS on MACRA: "Pick Your Pace" in 2017

As the AAN urged in our April comment letter to the Centers for Medicare & Medicaid Services (CMS) on the proposed MACRA regulations, the agency formally acknowledged last Thursday the many challenges facing physician practices during the implementation phase of MACRA. CMS subsequently released its proposed plan to make available four choices that will empower physicians to pick their pace of participation in the first MACRA performance period that begins on January 1, 2017. 

Under the proposed plan, choosing any one of the four options would ensure that you do not receive a negative payment adjustment (payment penalty) in 2019 based on your 2017 data: 

  • Full-year reporting that begins on January 1;
  • Partial-year reporting for a reduced number of days;
  • A “test” option under which physicians can report minimal amounts of data; or
  • Participating in an advanced alterative payment model (APM).

Additional supporting details about each of the options are expected to be released in the final rule, due on or before November 1. 

The plan will provide a pathway for those not quite ready for full implementation to avoid negative payment adjustments, while allowing those who are prepared to retain the option to achieve bonus payments. This plan signals that CMS is willing to hear and take action on our concerns, particularly when it comes to ensuring the highest chance of success in new payment systems for our members in solo and small practices.

AAN Submits Comment Letter to CMS on Proposed Fee Schedule

As we previously wrote in the Capitol Hill Report, in early July, the Centers for Medicare & Medicaid Services (CMS) released its proposed Medicare Physician Fee Schedule. The AAN thoroughly reviewed the proposed rule and recently submitted our comment letter with feedback for CMS. In our letter, we support the new add-on code that improves payment for visits that initiate chronic care management (CCM) services and increased payment for complex CCM codes. Our letter also advocates that CMS offer payment for the assessment and creation of care plans for beneficiaries with cognitive impairment and payment for critical care consultations furnished via telehealth. 

However, we would like CMS to publish additional information about its proposed codes and documentation guidelines. Our letter also addresses concerns with the Open Payments program, the reporting of data from ACOs, and changes to proposed appropriate use criteria requirements. Additionally, we joined several coalitions across a wide spectrum of medical associations to support increased reimbursement for cognitive specialists, telehealth services, and other positive changes for neurology in the Medicare Physician Fee Schedule. We expect to see the final rule from CMS in November. 

AAN Meetings Help Increase FAST Act Cosponsors

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

The AAN DC staff spent the last seven weeks during Congress' recess meeting with congressional staff about the Furthering Access to Stroke Telemedicine Act (HR 2799). The bill would allow Medicare to pay for stroke consultations via telemedicine in urban and suburban areas. Medicare already pays for these services in rural hospitals.

Our work paid off as we were informed by the author of the bill, Rep. Morgan Griffith (R-VA), that 14 more members of Congress had informed him that they were signing on as cosponsors. This brings the bill up to 159 cosponsors and we expect many more in September.

Last week we had a discussion with key staff from the House Energy & Commerce Committee and learned there is concern that there may not be a final health care bill moving before Congress adjourns at the end of September. 

Legislation impacting health care rarely moves through Congress as a standalone bill. Various ideas are packaged together into a larger bill. We have been eyeing several potential legislative vehicles for the FAST Act such as the 21st Century Cures bill that passed the House earlier, but E&C Chairman Fred Upton (R-MI) indicated last week that there is no way the House and Senate will come to a final agreement with the Senate on 21st Century Cures before the elections. If the House is able to put something together before adjournment, we are ready to add the FAST Act.

On the Senate side, I will be joining AAN Government Relations Committee Chair Nick Johnson, MD, this week for a meeting with Senate Finance Committee staff. The committee is chaired by Dr. Johnson's home state Senator Orrin Hatch (R-UT). Dr. Johnson has been working with Hatch's office to get a cost analysis of the bill which is essential prior to moving forward.  

If there are no more health-related bills that move through the current Congress, we will start again in the next session. This will be disappointing but we will be well on our way.