ASPS Comments on 2014 Proposed Physician Fee Schedule and Hospital Outpatient and ASC Payment Systems
Steps to Avoid Negative Payment Adjustments under PQRS and Value Modifier in 2015 Must be Completed in 2013
Posted November 20, 2013 -- The American Society of Plastic Surgeons and the American College of Surgeons are pleased to announce a shared scholarship open to members in good standing of both organizations. The scholarship supports attendance and participation in the "Executive Leadership Program in Health Policy and Management" which will take place June 8-14, 2014 at Brandeis University in Waltham, Massachusetts. The closing date for the receipt of applications is February 3, 2014.
Posted November 15, 2013 -- Those physicians and office managers awaiting the final rule for the 2014 Physician Fee Schedule should know that the Centers for Medicare and Medicaid Services (CMS) announced that due to the government shutdown in October, the release of many final rules, including the Physician Fee Schedule, has been delayed. CMS expects the final rule to be released by November 27.
ASPS will continue to monitor for its release.
Posted November 15, 2013 -- The end of the year serves as a reminder for physicians to prepare to report their quality measures to avoid the 2015 Physician Quality Reporting System (PQRS) adjustment. This adjustment of 1.5% will apply to covered professional services furnished by an eligible professional or group practice during 2015, but is based upon the reporting of quality measures during 2013. While the deadline for one option has already passed, two more opportunities exist to avoid the 2015 payment adjustment:
- Option 1: Meet the criteria for satisfactory reporting for the 2013 PQRS Incentive of 0.5%. These criteria vary depending on whether a physician is reporting measures or measures groups and how they report their measures.
- Option 2: Report at least one valid measure for one applicable patient via claims, participating registry or participating and qualified Electronic Health Record (EHR) vendor, or report at least one valid measures group via claims or participating registry. This second option is to avoid the 2015 payment adjustment only and has no incentive tied to it.
Physicians who do not currently have a mechanism for reporting quality measures should know that ASPS, jointly with CECity Registry developed a PQRS reporting tool for plastic surgeons, the PQRSwizard. The PQRSwizard is an easy to use online tool that helps physicians and other eligible professionals quickly and easily participate in PQRS by collecting, validating and submitting physician quality measures to CMS for payment. More information on the PQRSwizard and how to sign up can be found here.
Additional information about PQRS can be found on the CMS website.
Posted November 15, 2013 --The Breast Cancer Patient Education Act (S. 931/H.R. 1984) continues to gain cosponsors in Congress, with 11 House cosponsors and 9 cosponsors in the Senate. The legislation would direct the Secretary of the Department of Health and Human Services (HHS) to create an educational campaign to help women understand their options for reconstruction prior to mastectomy.
Senator Sherrod Brown (D-OH) and Senator Roy Blunt (R-MO) are the sponsors in the Senate, with Representative Leonard Lance (R-NJ) and Representative Donna Christensen (D-VI) sponsoring the legislation in the House.
This legislation requires the HHS Secretary to develop information about women's reconstruction options, in consultation with stakeholders, that can be distributed or have another qualified entity do so. Educational materials will inform women that breast reconstruction is possible at the time of their breast cancer surgery; that it can be delayed until after additional treatments; or that they may choose not to have breast reconstruction and be informed of other options including the availability of prostheses or breast forms. Any educational materials will also inform breast cancer patients that federal law mandates the coverage of breast reconstruction, even if the patient chooses to delay the reconstruction until after other treatments.
ASPS is ramping up advocacy efforts surrounding this bill on Capitol Hill.
Posted November 4, 2013 -- On Wednesday, October 30th, the Senate Finance and House Ways and Means Committees released a bipartisan, bicameral proposal to repeal and replace the flawed sustainable growth rate. While only in discussion draft form with no legislative language, the proposal lays out the major priorities of the two committees. The proposal builds off of the House Energy and Commerce Committee passed legislation but makes some significant changes. The most significant change included is a 10 year freeze of physician payments beginning in 2014, rather than the 5 years of 0.5% positive updates included in the Energy and Commerce legislation. Physicians who participate in alternative payment models with a two-sided risk model would be eligible for a 5% bonus payment.
Additionally, the proposal creates a Value-Based Performance Payment Program (VBP) which streamlines the various federal reporting programs and penalties into one, budget-neutral incentive program. The VBP would combine reporting for the Physician Quality Reporting System (PQRS), the Value-Based Modifier and the Electronic Health Records (EHR) Meaningful Use program. The penalties that would have been assessed under these three programs will be combined and remain in the physician payment pool. The VBP creates "assessment categories" for reporting which include quality measures, resource use, clinical practice improvement activities and EHR Meaningful Use. Physicians would be assessed a composite score based on their scores from the VBP categories and would receive payment adjustments based on their composite score. Because the program is budget neutral, payments for high performing professionals would be offset by payment reductions for poorer performing professionals. The proposal states that "professionals who treat few Medicare physicians" may be excluded from the VBP.
A major goal of the proposal is to encourage participation in alternative payment models (APM). The potential 5% payment update for participation in two-sided risk APMs and the score for clinical improvement activities, which includes participation in a Medicare APM, are attempts to move away from the fee for service system. Participants in APMs are also excluded from the VBP.
ASPS will be providing comments on the proposal to the committees and will continue to advocate for a full repeal of the SGR.
Posted October 10, 2013 -- On June 27, the Centers for Medicare & Medicaid Services (CMS) unveiled an updated version of the Physician Compare website with changes aimed at improving the information and usability of the site. Since its launch, there have been many issues raised about the accuracy of physician and practice information on the website. Physicians who find that their information is inaccurate or do not find themselves listed should follow these steps. Physician Compare pulls most physician information from the Provider, Enrollment, Chain, and Ownership System (PECOS). A physician's profile in PECOS needs to be listed as "active", have a specialty listed and at least one practice address listed in order to be accurately portrayed on Physician Compare. Once a physician has updated their information it can take four to six months to see the update on Physician Compare. If a physician logs into their PECOS account and finds their information is correct, CMS should be notified by sending an e-mail to PhysicianCompare@Westat.com. The e-mail should include the physician's name, specialty, address, NPI number and best method of contact and CMS will investigate further. CMS has provided step by step instructions on setting up or updating a physician's PECOS account here. All questions and issues can be directed to the Physician Compare team at PhysicianCompare@Westat.com. You may also contact Lance Kovacs at email@example.com.
Posted October 10, 2013 -- Beginning in 2014, all providers must report CQMs based on new requirements outlined in the Stage 2 final rule, regardless of what stage they are in. In preparation for this, the Centers for Medicare & Medicaid Services (CMS) has released a new resource, An Eligible Professional's Guide to Stage 2 of the EHR Incentive Programs, which provides a comprehensive overview of Stage 2 of the EHR Incentive Programs to eligible professionals (EPs). The guide outlines criteria for Stage 2 meaningful use, 2014 clinical quality measure reporting and 2014 EHR certification. Physicians can access a copy of this resource here. Additionally, more information on the EHR Incentive Programs can be found here. Questions can also be directed to Lance Kovacs at firstname.lastname@example.org.
Posted October 10, 2013 -- The Centers for Medicare & Medicaid require providers to report on clinical quality measures (CQMs) to demonstrate meaningful use under the EHR Incentive Programs. For the 2013 reporting year, there are two options for reporting CQMs for the Medicare EHR Incentive Program: the CMS Attestation System or through electronic reporting pilots.
Physicians submitting through attestation should follow these steps:
- Log in to the CMS Registration and Attestation system.
- Enter your data for the meaningful use core and menu objectives
- Report your CQM data directly from your certified EHR technology into the Attestation System
Eligible professionals (EPs) must report a total of six CQMs:
- Three core or alternate core measures (only report an alternate core measure if one of the core denominators is zero)
- Three additional measures from a list of 38
- If you are attesting to CQM data for the EHR Incentive Programs you may submit zero result for a CQM if the zero is the accurate calculation from your EHR
EPs may also submit CQMs through electronic reporting, or eReporting, pilots through the
PQRS-Medicare EHR Incentive Pilot.
It is important to remember that some CQMs cannot be met during the reporting period chosen by the provider and so exclusions are available for those CQMs. For example, many CQMs for EPs require a minimum of two visits for a patient to meet the denominator criteria. Exclusions do not count against a provider's attestation requirements.
Posted October 10, 2013 -- The Centers for Medicare & Medicaid Services (CMS) has announced that Quality Resource and Use Reports (QRURs) are now available for group practices with 25 or more eligible professionals (EPs). Authorized representatives of groups can access the QRURs here using an Individuals Authorized Access to the CMS Computer Services (IACS) account. CMS strongly encourages representatives of groups to sign up for a new IACS account or modify an existing account here as soon as possible in order to be able to access the QRURs. A Quick Reference Guide that provides instructions on how to obtain your 2012 QRUR is available in the "Downloads" section of the QRUR Templates and Methodologies webpage.
Posted September 11, 2013 -- There is now less than a month remaining before the September 23 deadline for physicians and business associates to be in compliance with the new Health Insurance Portability and Accountability Act of 1996 (HIPAA) final rule. With the impending deadline, ASPS is sharing two additional resources.
The first is from the New York County Medical Society (NYCMS) that highlights an action plan for physicians to prepare for these changes. The document answers many of the questions that physicians and office managers have on what new protocols must be followed. This document is for ASPS members only and can be obtained by contacting Lance Kovacs at email@example.com.
The second is a tool kit developed by the American Medical Association (AMA) that includes a HIPAA guide, frequently asked questions as well as sample notice of privacy practices and business associate agreement. You can access this information on the AMA website here.
ASPS Comments on 2014 Proposed Physician Fee Schedule and Hospital Outpatient and ASC Payment Systems
Posted September 11, 2013 -- On September 6, the American Society of Plastic Surgeons (ASPS) provided comments on behalf of its members to the Centers for Medicare & Medicaid Services (CMS) on two proposed rules for 2014: Medicare physician fee schedule and the hospital outpatient prospective payment system and quality reporting programs. ASPS registered several concerns about:
- The increased number of measures that would be required for satisfactory reporting under the Medicare Physician Quality Reporting System (PQRS)
- The search functionality on the Medicare Physician Compare website
- The Agency's plans to cap payments to services performed in the non-facility setting when those payments are greater than what is paid when the same service is performed in either the hospital outpatient or ambulatory surgical center facility setting
- The CMS proposal to unconditionally package all drugs and biologicals that function as supplies or devices in a surgical procedure
You can read ASPS' comment letter to CMS on the CY 2014 physician fee schedule here and the comment letter on the hospital outpatient and ASC payment systems here. ASPS anticipates the final rules will be published in early November and will provide an update for members.
Steps to Avoid Negative Payment Adjustments under PQRS and Value Modifier in 2015 Must be Completed in 2013
Posted September 11, 2013 -- Physicians who provide Medicare Part B physician fee schedule (PFS) covered services should be aware of negative payment adjustments planned for CY 2015. These include:
- A -1.5% adjustment under the Physician Quality Reporting System (PQRS) for individual eligible professionals (EPs) who do not submit data on PQRS quality measures to CMS in 2013.
- A -1% adjustment under the Value-Based Payment Modifier (VM) for physicians in groups of 100 or more EPs who submit claims to Medicare under a single tax identification number who fail to report under PQRS in 2013.
EPs can submit data through the traditional PQRS methods (claims, registry and EHR) to avoid the 2015 payment adjustment and potentially earn a 2013 incentive of 0.5%. To avoid the payment adjustment only, EPs can request that the Centers for Medicare and Medicaid Service (CMS) calculate their quality data from administrative claims by using the instructions and information available in the Quick Reference Guide for Individual EPs. EPs must register for the CMS-calculated administrative claims option by October 15, 2013.
For purposes of the PQRS and VM payment adjustments, group practices of fewer than 100 are not subject to the value modifier for 2015. Groups with 2-99 EPs can still register to report under the PQRS Group Practice Reporting Option (GPRO) to avoid the 2015 PQRS payment adjustment and potentially earn a 2013 PQRS incentive payment of 0.5%. Groups with 100 or more EPs are required to register for purposes of avoiding a negative VM payment adjustment via the web-interface GPRO and registry. To avoid payment adjustments only, groups can request that CMS calculate their quality data from administrative claims. Group practices must register and select their reporting method by October 15, 2013 by using the instructions and information available in the Quick Reference Guide for Group Practices.
Additional information and resources are available on the PQRS website and the Physician Feedback/VM Self Nomination/Registration website. If you have questions, please contact the QualityNet Help Desk at 866-288-8912 or via firstname.lastname@example.org. You may also contact Lance Kovacs at ASPS at email@example.com.
Posted September 11, 2013 -- Those eligible professionals (EPs) or groups who participated in the 2012 Physician Quality Reporting System (PQRS) program can now access their individual or group feedback report from the Centers for Medicare & Medicaid Services (CMS).
EPs can access their feedback report at the National Provider Identifier (NPI) level by submitting a request through the Communication Support Page or at the Taxpayer Identification Number (TIN) level through the Physician and Other Health Care Professionals Quality Reporting Portal via QualityNet.
Groups who participated in 2012 PQRS Group Practice Reporting Option (GPRO) will be able to access PQRS feedback through 2012 Quality and Resource Use Reports (QRURs) on September 16, 2013. Authorized representatives of practices with 25 or more EPs can access the QRURs at https://portal.cms.gov using an Individuals Authorized Access to CMS Computer Services (IACS) account.
Posted September 11, 2013 -- Those EPs and groups who participated in the 2012 Electronic Prescribing (eRx) Incentive Program can download their Taxpayer Identification (TIN) - level reports on the Physician and Other Health Care Professionals Quality Reporting Portal available via QualityNet.
Those physicians who were successful reporters or prescribers in 2012 should see their incentive payments this fall. Questions about your reports or incentive payments should be directed to the QualityNet Help Desk at 1-866-288-8912 or Qnetsupport@sdsp.org.
Posted September 11, 2013 -- On Aug. 16, Illinois Governor Pat Quinn signed legislation (H.B. 3175) that will help ensure breast cancer patients are informed of their reconstructive options. The new law, which was modeled after the ASPS federal bill, requires the Illinois Department of Health to develop and implement an education campaign to inform breast cancer patients, especially those in racial and ethnic minority groups, of the availability and coverage of breast reconstruction. ASPS supported the efforts of Rep. Kay Hatcher, the bill's sponsor, to pass this legislation.
Posted September 11, 2013 -- The Alabama Breast Cancer Patient Education Act of 2013 (S.B. 22), which was signed into law earlier this year by Governor Robert Bentley, became effective Aug. 1. The new law requires the Alabama Department of Public Health (ADPH) to develop standardized information for breast cancer patients about treatment and breast reconstruction options and insurance coverage availability for these treatments. Certain physicians are then required to disseminate the summary to breast cancer patients.
Posted August 13, 2013 -- As the September 23 deadline for physicians and business associates to be in compliance with the new Health Insurance Portability and Accountability Act of 1996 (HIPAA) final rule nears, ASPS is sharing some useful links and other resources for practices still struggling to ensure their compliance with the new rule.
The Centers for Medicare & Medicaid's (CMS) Office of Civil Rights (OCR) has created several useful tools for physicians and business associates such as the Business Associates Contracts page that provides background on the new contracts that are required between physicians and a business associate as well as a sample agreement that can be used. OCR also has created the Fast Facts for Covered Entities page which gives physicians quick answers on what they should and should not be doing as it relates to the disclosure of personal information. Please note that these resources only apply to the federal guidelines that must be followed and do not take into account state regulations that vary and may be more stringent than the federal rule.
Additionally, the Health Insurance Portability and Accountability Act of 1996 Collaborative of Wisconsin (HIPAA COW), a group of Wisconsin healthcare agencies of both the public and private sector, has developed an extensive library of checklists, sample contracts, privacy notices and protocols geared towards providers dealing with HIPAA compliance. You can see the list of their resources here. These documents are free to download and use as long as you follow their Copyright notice at the top of each document. Again, this information is geared toward meeting the compliance of the federal rule. Members should also be aware of any state regulations impacting the use of personal health information.
ASPS will continue to monitor various sources for other useful resources and tools in upcoming weeks for both HIPAA compliance and other federal regulatory issues that impact our membership.
Use of app technology helps to bring greater transparency to payments and other financial interactions between doctors and health care industry.
Posted August 8, 2013 -- On July 17, CMS introduced two free mobile device applications (apps) to help physicians and health care industry users to track their payments and other financial transfers the industry will report under the Open Payments program (Physician Payments Sunshine Act). Created by a provision of the Affordable Care Act, Open Payments creates greater public transparency about the financial transactions between doctors, teaching hospitals, drug and device manufacturers, and other health care businesses.
CMS has made these apps available to facilitate accurate reporting of required information, which will be available to the public and will be published annually on the Open Payments website. To support the "Open Payments" program, CMS designed the mobile applications (one each for physicians and health care industry users) merging this proven and efficient format with real-time 24-hour tracking technology. The apps offer on-the-go convenience for users to track financial data. Both apps are compatible with the iOS (AppleTM) and Android platforms; they are available free through the iOS AppleTM Store and Google PlayTM Store.
Posted August 1, 2013 -- On February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) released the final rule regarding Transparency Reports and Reporting of Physician Ownership or Investment Interests (also known as the "Sunshine Rule"). Among other things, this final rule requires applicable manufacturers of drugs, devices, biologicals, or medical supplies covered by Medicare, Medicaid or the Children's Health Insurance Program (CHIP) to report annually to the Secretary certain payments or transfers of value provided to physicians or teaching hospitals ("covered recipients").Affordable Care Act's "Sunshine Rule" Increases Transparency in Health Care
Posted July 15, 2013 -- On January 23, 2013, Congressman Phil Roe, MD (R-TN) re-introduced H.R. 351, the "Protecting Seniors Access to Medicare Act of 2013." This bipartisan legislation currently has 192 cosponsors and would repeal the Independent Payment Advisory Board (IPAB). On February 14, 2013 Senator John Cornyn (R-TX) introduced companion legislation in the Senate, and the bill has garnered 36 cosponsors. ASPS strongly supports this legislation.
Posted July 1, 2013 -- Members of the American College of Surgeons and the American Society of Plastic Surgeons are invited to apply for the Paul Farmer Global Surgery Fellowship, a one- to two-year program that will give a surgeon the opportunity to study the role of surgical care in population-based health care in resource-poor settings. Final applications are due October 1, 2013.
This fellowship, which will begin July 1, 2014, is available in two tracks and is open to surgeons who have completed residency (clinical or research track) or surgical residents who are taking a scheduled break in residency to conduct research (research track). Plastic and reconstructive surgeon John G. Meara, MD, FACS, chair of the ACS Legislative Committee and a member of the ACS Health Policy and Advocacy Group, associate professor at Boston (MA) Children's Hospital, and professor at Harvard University, will lead the program with general surgeon Mike Steer, MD, FACS, Beth Israel Hospital, Boston. As part of the fellowship, participants may opt to pursue a master's degree in public health at the Harvard School of Public Health. View additional information and application instructions.
Posted May 15, 2013 -- The American Recovery and Reinvestment Act (ARRA) of 2009 authorized The Centers for Medicare & Medicaid Services (CMS) to provide financial incentives to physicians that demonstrate Meaningful Use of certified electronic health record (EHR) technology. Physicians will need to engage in meaningful use of EHRs by 2015 to avoid 1% penalty in 2015, 2% penalty in 2016, and a 3% penalty in 2017; penalty could increase up to 5% by 2021.
This online interactive course demonstrates key items plastic surgeons should know about Meaningful Use - Stage 1. Additionally, 0.5 Patient Safety credit can be earned.
Posted April 15, 2013 -- The Centers for Medicare and Medicaid Services (CMS) has recently announced that ICD-10 is moving forward for the October 1, 2014 deadline. The AMA stated that they are not planning to further pursue a delay. The CMS implementation guides have been updated and provide detailed information for planning the ICD-10 transition: ICD-10 Implementation Guide for Small and Medium Practice. More information: ICD-10 Provider Resources.
ASPS is planning to provide more education on ICD-10-CM in the Plastic Surgery News, at the ASPS Coding Workshops and ASPS Annual Meeting in San Diego.
Posted March 22, 2013 -- On February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) released the final rule regarding Transparency Reports and Reporting of Physician Ownership or Investment Interests (also known as the "Sunshine Rule"). Among other things, this final rule requires applicable manufacturers of drugs, devices, biologicals, or medical supplies covered by Medicare, Medicaid or the Children's Health Insurance Program (CHIP) to report annually to the Secretary certain payments or transfers of value provided to physicians or teaching hospitals ("covered recipients").
Posted December 12, 2012 -- ASPS joined the Surgical Coalition in advocating for this bill recently introduced in the House by Congresswoman Diane Black (R-TN). H.R. 1331 would create a "hardship exemption" for small practices and physicians in and near retirement to avoid workforce shortages as physician practices and hospitals transition to EHRs.