Take Your Seat at the Table!
Thursday, May 24, 2018 | Pat White
The Board of the Cardiology Advocacy Alliance (CAA) recently traveled to Washington, DC to carry its message to Congress. Marshall Brachman, CAA lobbyist, arranged for the Board to meet with a number of Congressional members and committee staff. Our focus was on members of the three committees with Medicare jurisdiction: Senate Finance, House Ways & Means, and House Energy & Commerce. We also met with the Doctors Caucus and several other Congressional members.
Although there are many issues floating around Congress, they are really focused on the opioid crisis. They were, however, eager to hear our issues. We took advantage of the opportunity to educate Congress on a number of issues (outlined below). An overarching message to Congress was to reduce the administrative burden and unintended consequences of legislation and CMS regulations. CAA Board members were very effective in outlining examples of how administrative burden has eroded the physician/patient relationship, decreased access to care, decreased physician satisfaction, added administrative cost, etc. Many anecdotes were shared which helped to paint a clear picture of the negative impact of these laws and regulations.
We were invited to attend the bipartisan Health Care Innovation Caucus supported by a diverse group of health care organizations from across the country. The caucus will advance a legislative agenda that encourages innovative policy ideas to improve the quality of care and lower costs for consumers.
I strongly encourage you to develop a relationship with your Senators and Representatives . . .They need to hear your concerns.
Several legislators encouraged us to visit more often to keep our issues on the front burner. Marshall Brachman is on the Hill every day sharing our story, but visiting 2-3 times per year will be considered.
Alternative Payment Models
- Bundled Payment Models should be voluntary. We need time to learn how to operate, as does Medicare. We prefer procedure-based bundles and not condition-based bundles. If condition-based bundles are ever included, patient attribution must be fixed. Target prices need to exclude new technologies. For example, Intensive Cardiac Rehab (ICR) programs have been shown to improve patient care, but there is significant cost in starting these programs. ICR cost should not be included in the calculation of target prices to ensure there are no unintended consequences.
- MIPS: We need more information before consideration of the elimination of MIPS as recommended by MedPAC.
- Advanced APMs: To achieve the 5% Advanced APM bonus, a group’s revenue from the Advanced APM must be at least 25% or 20% of their patients must be in the APM. These QP criteria ramp up to 50%/35% after the first year. We believe this is too difficult to attain for most providers. Keep it at 25%/20%. CAA also advocates that the current rule as follows should be permanent: One NPI (i.e., physician) meeting the QP criteria qualifies the other NPIs (i.e., physicians) within the same TIN group to qualify as QPs. CMS should develop programs that more easily qualify for Advanced APM status and all aspects of MACRA that assign penalties/rewards to individual physicians be suspended until an accurate and proven patient attribution methodology can be determined.
Fraud and Abuse Laws
- Regulations should be adapted to create legal safe zones to support new value-based payment models. Compensation agreement oversight should be removed from Stark Law, and remain solely under the Anti-Kickback Law.
Simplification of Evaluation & Management (E&M) Selection
- CMS is asking for input on simplifying the selection process for E&M codes. We strongly support simplification but we want to ensure the replacement system doesn’t cause other administrative burdens and doesn’t impact HCCs.
Promoting Interoperability (formerly Advancing Care Information, formerly Meaningful Use)
- Primary focus should be on promoting comprehensive interoperability among disparate EHR systems (i.e. system to system), and vendors should be allowed adequate time to develop the most appropriate platforms. Uniform federal standards need to be developed for technical EHR certification.
Site Neutrality – Off-Campus Providers
- No additional changes should be made regarding this issue. Hospitals spent money to convert to provider-based facilities. They followed the rules that were in place so CMS shouldn’t make anything retroactive.
I strongly encourage you to develop a relationship with your Senators and Representatives. Visit them when they are in town, invite them for a meeting and tour of your facility, host a fundraiser. They need to hear your concerns. The CAA is happy to support you with advice and talking points.
As someone once said, “If you are not at the table, you are on the menu!”
MedAxiom’s blog post is published every Thursday at www.medaxiom.com/blog
Illustration: Lee Sauer
About the Author
Pat White, MPH, Senior Advisor of MedAxiom, is a trusted cardiovascular healthcare leader and statesman. Pat has been in the healthcare management field for over 40 years. Prior to joining MedAxiom, Pat was in medical group practice management for 17 years. He spent 13 years with the Henry Ford Health System, including five years as the Administrator for the Department of Internal Medicine. He also served as the Executive Director of Michigan Heart, a 36-member cardiology practice in Ann Arbor.
Pat does senior consulting work and currently serves on the board of the Cardiology Advocacy Alliance.
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