Holy MACRA! Mark D. Kaufmann, M.D. Associate Clinical Professor Department of Dermatology Icahn School of Medicine at Mount Sinai October 27, 2017

Transcription

1 Holy MACRA! Mark D. Kaufmann, M.D. Associate Clinical Professor Department of Dermatology Icahn School of Medicine at Mount Sinai October 27, 2017

2 DISCLOSURE OF RELEVANT RELATIONSHIPS WITH INDUSTRY Mark D. Kaufmann, MD What s New in Coding Holy MACRA Modernizing Medicine, Inc Stock Options

3 NPRM 2018 MPFS On July 13, 2017 CMS put the following Notice for Proposed Rule Making into the Federal Register. In the Proposed Rule, there are several fee schedule changes for 2018 that are very important.

4 NPRM 2018 MPFS CPT CODE 2017 Payment Amount 2018 Payment Amount Percent Difference $ $ % $72.14 $ %

5 Treating AKs in 2018 CMS has proposed several changes in the fee schedule that- if finalized- will take effect on January 1, They have also added two new codes for Photodynamic Therapy (PDT)

6 CPT Code Photodynamic therapy by external application of light to destroy premalignant and/or malignant lesions of the skin and adjacent mucosa (eg, lip) by activation of photosensitive drug(s), each phototherapy exposure session NOTE: PDT is billed with J7308 Aminolevulineic acid HCL, 20% single Unit dose.

7 NPRM Fee Schedule Changes

8 NPRM Fee Schedule Changes CPT CODE 2017 Payment Amount 2018 Payment Amount Percent Difference $ $ % 96X73 NA $ NA 96X74 NA $ NA

9 NPRM Fee Schedule Changes CPT CODE 2017 Payment Amount 2018 Payment Amount Percent Difference $67.83 $ % $5.74 $ $ $

10 MACRA H.R. 2 Passed by the House on 3/26/15 (392-37) Passed by the Senate on 4/14/15 (92-8) Signed into law by President Obama 4/16/15 The Medicare Access and CHIP Reauthorization Act of 2015 MACRA CMS releases 2498 page Final rule for MACRA 11/4/16

11 MACRA Repealed the SGR (Sustainable Growth Rate) avoiding a 21% pay cut Mandates The Merit based Incentive Payment System begin in 2019 (MIPS) Those in Alternative Payment Models (APMs) will be excluded from the MIPS program

12 MACRA PREVENTED CMS FROM PULLING THE GLOBAL PERIODS FROM OUR CODES!

13 17000 Work RVU = Bundled visit= 0.48 Work RVU after Global Period Removed???

14 CPT Codes commonly used that have a 10-day global period 17000, Destruction of AKs 17110, Destruction of Benign Lesions 172xx Malignant Destructions 114xx, 116xx Excisions- Benign/Malignant 1203x, 131xx Intermed/Complex Repairs

15 SGR RIP! SEC PAYMENT FOR GLOBAL SURGICAL PACKAGES. (a) IN GENERAL. Section 1848(c) of the Social Security Act (42 U.S.C. 1395w 4(c)) is amended by adding at the end the following new paragraph: (8) GLOBAL SURGICAL PACKAGES. (A) PROHIBITION OF IMPLEMENTATION OF RULE REGARDING GLOBAL SURGICAL PACKAGES. (i) IN GENERAL. The Secretary shall not implement the policy established in the final rule published on November 13, 2014 (79 Fed. Reg et seq.), that requires the transition of all 10-day and 90-day global surgery packages to 0-day global periods.

16 SGR - RIP! (B) COLLECTION OF DATA ON SERVICES INCLUDED IN GLOBAL SURGICAL PACKAGES. (i) IN GENERAL. Subject to clause (ii), the Secretary shall through rulemaking develop and implement a process to gather, from a representative sample of physicians, beginning not later than January 1, 2017, information needed to value surgical services. Such information shall include the number and level of medical visits furnished during the global period and other items and services related to the surgery and furnished during the global period, as appropriate. Such information shall be reported on claims at the end of the global period or in another manner specified by the Secretary.

17 99024 Postoperative follow-up visit, normally included in the surgical package, to indicate that an evaluation and management service was performed during a postoperative period for a reason(s) related to the original procedure.

18 99024 IF I won t be paid.why bother? IF you live in the following states it started to matter in July Any group of 10 or more physicians/qhp needs to start reporting code on ALL visits that take place in the global period.

19 99024 States Florida Ohio Kentucky Oregon Louisiana Rhode Island Nevada New Jersey North Dakota

20

21 Performance Period and Payment Year Performance Year 1 Payment Year 1

22 Two Tracks: MIPS and Advanced APMs MIPS Options Advanced APM Option Test the program report on a limited set of data to avoid penalty only Partial participation report more data for at least 90 days to receive a small incentive Full participation report all elements for 90 days or more to receive full incentive * Not reporting in 2017 will result in a 4% payment penalty in 2019 Join an Advanced APM Must receive 25% of Medicare Part B payments or see 20% of Medicare Part B patients through an advanced APM in 2017 Excluded from program if you: Are in the Medicare program for the first year Have less than $30,000 per year in allowed Medicare Part B charges See fewer than 100 Medicare Part B patients per year Potential to earn a 5% incentive payment in 2019

23

24 Track One: MIPS (Merit-based Incentive Payment System) In 2017, the MIPS score will factor performance in 3 of 4 weighted categories: Quality (60% Year 1) Replaces PQRS Improvement Activities (15% Year 1) Advancing Care Information (25% Year 1) Cost (0% ) Report on at least 50% of Medicare and non- Medicare patients in the denominator of the measure for QCDR, QR and EHR reporting Report on 6 measures from the dermatology-specific measure set for full credit Report on 4 mediumweighted or 2 high-weighted activities for full credit Small practices (15 or fewer providers) can report on 1 highweighted or 2 medium-weighted activities for full credit Replaces EHR meaningful use Report on 5 measures for full base score credit Flexible scoring Supports the exchange of patient information Eliminated for 2017 Category will increase to 30% of score by 2021

25 2017 MIPS Performance

26

27 2017 is a Transition Year Pick Your Pace 2017 is a Transition Year Pick Your Pace 2017 is r Pick Your Pace Test Test Pace: Pace: Avoid Avoid Penalties Penalties Report ONE of the following: One measure in the quality performance category at least one time* One activity in the improvement activity category Five required measures making up the base score of the advancing care information (ACI) category Partial Participation: Partial Participation: Small Incentive Small Incentive Report ONE of the following for at least 90 days: More than one quality measure in the quality performance category More than one improvement activity More than the five required measures in the ACI category Full Participation: Full Participation: Larger Incentive Larger Incentive Report ALL of the following for at least 90 days: Six quality measures in the quality performance category One high-weighted improvement activity or two medium-weighted improvement activities Five required measures making up the base score of the ACI category. *The AAD strongly recommends practices report more than one measure or report at least one measure over a 90-day period as an insurance policy in the event of submission issues or inaccuracies. Failure to correctly report one measure or activity in 2017 will result in a 4% penalty in 2019.

28 MIPS: Dermatology Quality Measure Set PQRS ID Measure Title Outcome/High Priority Diagnosis/Area of Interest 130 Medications: Current Medications Documented in Medical Record High Priority Medications 137 Melanoma: Continuity of Care Recall System High Priority Melanoma 138 Melanoma: Coordination of Care High Priority Melanoma 224 Melanoma: Overutilization of Imaging Studies High Priority Melanoma 226 Tobacco Use: Screening and Cessation Intervention Tobacco Use 265 Biopsy Follow-Up High Priority Biopsy 317 High Blood Pressure: Screening and Follow-Up Documented High Blood Pressure 337 Psoriasis: Tuberculosis Prevention for People with Psoriasis or Psoriatic Arthritis on a Biologic Immune Response Modifier Psoriasis 374 Closing the Referral Loop: Receipt of Specialist Report High Priority Referrals 402 Tobacco Use and Help with Quitting Among Adolescents Tobacco Use 410 Psoriasis: Clinical Response to Oral Systemic or Biologic Medications Outcome and High Priority Psoriasis

29

30

31

32

33

34

35

36

37

38

39

40 Skate to where the puck is going, not to where it is. Wayne Gretzky

41 Disruptive Innovation an innovation transforms an existing market or sector by introducing simplicity, convenience, accessibility, and affordability where complication and high cost are the status quo. Initially, a disruptive innovation is formed in a niche market that may appear unattractive or inconsequential to industry incumbents, but eventually the new product or idea completely redefines the industry.

42

43

44

45 Dermatology?

46 Volume to Value

47 Volume to Value We must shift away from a fee-for-service system that reimburses only on volume and move toward a system that holds providers accountable for outcomes and allows them to innovate. Providers need the freedom to design and offer new approaches to delivering care. Our goal is to increase flexibility by providing more waivers from current requirements. -- Seema Verma. WSJ 9/20/17

48 Volume to Value No longer paid for how much you do, but rather on your results Financial incentive is reversed as you try to see the patient less often, do fewer procedures, AND try to shift to less expensive interventions (procedures and/or pharmacologic) Consolidation into larger group practices Increase use of extenders Increase use of Telemedicine Increase treatment of forgotten disease states (e.g. wound healing, genital dermatoses)

49 APMs Alternative Payment Models Can include: Medical homes, Accountable Care organizations (ACOs), Bundled Payments

50

51

52

53

54

55

56

57

58

59

60 Data is the new Currency of Healthcare

61

62

63

64

65 Don t find fault - find a remedy. Henry Ford

66