2017 Physician Payment Advocacy Highlights
Published on: November 29, 2017
The
Medicare and CHIP Reauthorization Act of 2015 (MACRA)
ASH provided comments to the
Centers for Medicare and Medicaid Services (CMS) in April on the episode-based
cost measure development for the Quality Payment Program (QPP), the new pathway
for how Medicare will pay physicians, created through the Medicare and CHIP
Reauthorization Act (MACRA). The
episode-based cost measures will be used to determine physician reimbursement under
the Cost Performance Category, one of four performance categories in the QPP. In May, ASH launched a new webpage devoted to keeping
members up-to-date on the QPP. The
website features information on ASH’s partnership with Healthmonix, a 2017
Qualified MIPS Registry. ASH members can
now sign up to report data for the 2017 performance year for the Merit-based
Incentive Payment System (MIPS) through Healthmonix’s MIPSPRO. ASH and Healthmonix hosted a joint webinar on
November 13, 2017 to provide guidance on how to use the MIPSPRO registry.
In August, ASH submitted
comments on the proposed rule for Year 2 of Medicare’s Quality Payment Program
(QPP). ASH thanked CMS for the
adjustments made to accommodate small practices, the efforts to reduce
administrative burden, and continuing to allow the use of 2014 Edition
Certified Electronic Health Record Technology (CEHRT). ASH supported the
proposal to maintain the weight of zero for the cost performance category for
the second year of the program, emphasizing that CMS must finalize the required
risk adjustment, attribution methodologies, and ensure that there are adequate
episode measures for all specialties before this category counts towards a
clinician’s final score. The final rule was released in November. An oral
report regarding the rule’s impact on hematologists will be provided to the
Committee on Practice during its December meeting. In addition, the full analysis of the rule
will be posted on ASH’s website soon.
2018
Medicare Inpatient Hospital Rule
ASH offered comments on the 2018
proposed rule for the Inpatient Prospective Payment System (IPPS). The rule
determines payment levels and related provisions for Medicare patients who are
admitted to the hospital. ASH supported increased reimbursement for hematopoietic
cell transplantation (HCT), reassignment of autologous and allogenic
transfusion codes, and two new add-on payments for VYXEOS and Kite’s
axicabtagene ciloleucel. ASH also
provided extensive comments on evaluation and management document requirements,
as it relates to reducing administrative burden. The final IPPS rule was issued in August. Although the final rule did not address the
reimbursement for HCT, it did finalize that the autologous and allogenic
transfusion codes would maintain their original assignment, which ASH supported.
Additionally, Kite’s application for a new
add-on payment was pulled prior to the issuance of the final rule and VYXEOS
was considered ineligible because the product had not met the July 1 deadline
for approval by the US Food and Drug Administration.
2018
Medicare Physician Payment Rule and Hospital Outpatient Prospective Payment
System Rule
In July, the Centers for
Medicare and Medicaid Services (CMS) released their annual proposed changes to
the Medicare Physician Fee Schedule (PFS) that would be implemented on January
1, 2018. The rule updates payment policies and payment rates for services
provided in the physician office. ASH commented on a number of proposed
valuations of specific CPT codes, including codes for therapeutic apheresis,
bone marrow aspiration, chemotherapy aspiration, and hydration. Additionally, the Society commented on
proposed payment rates for non-excepted items and services furnished by
non-excepted off-campus provider-based departments of a hospital and on CMS’s
proposal to review and revise the Evaluation & Management (E/M)
documentation requirements.
The Hospital Outpatient
Prospective Payment System (HOPPS) proposed rule was also released in July.
This rule outlines changes in payment policies for services rendered in
hospital outpatient settings. ASH commented on CMS’s proposal to drastically
reduce payments to the 340B program and on coding related to bone marrow
transplants and hematopoietic cell harvesting. Additionally, ASH opposed the proposal to
package low cost drug administration services and on the payment for
hematopoietic stem cell transplantation.
The final rules for the PFS and
HOPPS were published in November and an oral report regarding the rules’ impact
on hematology services will be provided to the Committee on Practice during its
December meeting. In addition, the full
analysis of the rules will be posted on ASH’s website soon.
AMA,
CPT Coding, RUC, and Medicare Payment Policies for Hematology-Specific Services
ASH was officially voted back
into the American Medical Association (AMA) House of Delegates (HOD) at the AMA
HOD meeting in June. Dr. Gamini Soori
and Dr. Chancellor Donald, both members of ASH’s Committee on Practice, serve
as delegate and alternate delegate to the AMA HOD and represented ASH at this
meeting and the AMA Interim Meeting in November. Beginning in 2018, ASH will also have a
delegate for the Resident and Fellow Section (RFS) of the AMA HOD. Dr. Amar
Kelkar, soon to be a hematology oncology fellow, will serve as an extra voice
in supporting issues relevant to and important to ASH. Dr. Samuel Silver continues to serve as the
ASH representative for the AMA CPT Advisory Committee and the AMA RUC Advisory
Committee. Dr. Silver, along with ASH staff, attends the CPT and RUC meetings
to ensure that hematology services continue to be properly coded and
appropriately paid. ASH also started working closely with ASBMT on issues
related to coding and reimbursement for CAR-T therapy after the FDA approved
the first two CAR-T therapies in August and October of 2017.
ASH continues to be actively
involved in the Cognitive Care Alliance, which was established to ensure that
evaluation and management (E&M) service code definitions and valuations
accurately reflect the intensity of the cognitive work performed. ASH staff
participated in meetings on Capitol Hill to ask key policy makers to contact
the Centers for Medicare & Medicaid Services (CMS) and urge them to conduct
the research necessary to study the outpatient E&M codes. The existing
E&M codes do not properly describe the work performed by physicians,
including hematologists, who primarily treat chronically ill patients. ASH is hopeful that a CMS-commissioned study
will determine what improvements could be made to the description of work and
documentation requirements so that new codes could be added that better
describe the services provided by hematologists.
Medicare
Contractor Advisory Committee Meeting
In July, ASH, in conjunction
with the American Society of Clinical Oncology, held the annual meeting of the
hematology / oncology carrier advisory committee (CAC) network. This annual event brings together the
hematologists and oncologists who serve as representatives to regional Medicare
Contractors, Medicare Contractor Medical Directors, leaders from hematology and
oncology state societies, and members of ASH and ASCO practice committees. The
meeting is intended to provide attendees with a better understanding of the CAC
process; discuss issues of common concern and develop solutions; and improve
the overall CAC process throughout the year. Topics at this year’s meeting included
reimbursement for next generation sequencing, allogeneic SCT and CAR-T
therapies for lymphoma, MACRA, coverage of off label medications, and use of
chronic red cell exchange (apheresis) in the management of adults with sickle
cell disease.
Center
for Medicare and Medicaid Innovation
ASH participated in a meeting at
the Center for Medicare and Medicaid Innovation (CMMI) to provide feedback on
the Oncology Care Model (OCM) and also arranged for CMMI staff to meet with ASH
members who are participating in this new payment model during the ASH Annual
Meeting. ASH also met with CMMI staff to discuss ideas for a delivery and
payment model for patients with sickle cell disease.
ASH
Committee on Practice Capitol Hill Day
Members of the ASH Committee on
Practice visited more than forty congressional offices to advocate for issues
related to sickle cell disease and drug access.
The ASH advocates encouraged congressional offices to provide dedicated
funding for sickle cell disease surveillance, outreach, and education programs to
the Centers for Disease Control and Prevention’s (CDC) Blood Disorders Division
in the fiscal year 2018 Labor, HHS, Education Appropriations bill. The group
also asked members of Congress to support legislation (the Cancer Drug Parity
Act, H.R. 1409), which would require insurance companies to cover oral
chemotherapy at the same rate as intravenous chemotherapy.
ASH
Palliative Care Working Group
ASH launched a Palliative Care
Working Group, comprised of members of the Committee on Practice, the Committee
on Government Affairs, and the Committee on Quality. The group will examine
what ASH can do to promote further understanding of palliative care as it
relates to the practice of hematology. The group will recommend and explore
actions that ASH can take related to palliative care in the following areas:
education of ASH members, guidelines and evidence-based practice, payment and
reimbursement, and policy and legislation. The group chose to focus their
efforts on coverage for palliative blood transfusions in hospice care.
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