Aug. 24, 2017: National Advocacy Update

The Medicare Access and CHIP Reauthorization Act (MACRA) ensured that Medicare Meaningful Use (MU) payment adjustments would discontinue in 2019, which is why—given MU's typical two-year look-back period—most physicians participating in MIPS in 2017 do not need to also participate in MU in 2017. However, physicians who have never reported on MU (i.e., physicians who are eligible to participate in MU but have never attested before) will receive a negative payment adjustment in 2018, since the look-back period for first-time reporters is only one year.

To ease the burden on these physicians, the AMA urged CMS to develop a one-time hardship exception, ensuring that first-time reporters in 2017 did not have to simultaneously participate in MU and the ACI component of MIPS simply to avoid a negative payment adjustment in 2018.

While the application and instructions state the physicians must plan on reporting ACI measures in 2017, physicians applying for the hardship exception can still decide to participate in the MIPS "pick your pace" test option—allowing them to report on one quality measure for one patient to avoid a payment penalty in 2019. In other words, physicians who participate in MIPS at the test pace are not required to report data on ACI to use the hardship exemption.

The hardship application allows multiple physicians from one practice to be included on the same application. Physicians or their practice managers can attach the application to an email and send it to [email protected] or fax it to (814) 456-7132. It must be completed and submitted to CMS no later than Oct. 1. Physician practices should save the application for their own records prior to submission.

As a reminder for all eligible Medicare, Medicaid, and hospital-based physicians, CMS now has three separate electronic health record (EHR) incentive programs. Participation requirements, incentives and penalties differ by program. Eligible physicians should be aware of which program applies to them, the incentives that are still available, how to avoid penalties, and the length of the reporting periods.

ACI component of MIPS

• ACI replaces the Medicare Meaningful Use program for "MIPS eligible physicians."
• In 2017, MIPS eligible physicians are defined as those who bill Medicare more than $30,000 in Part B-allowed charges a year and provide care for more than 100 Medicare patients a year
• MIPS participation can result in up to a 4 percent bonus in 2019, depending on the physician's total MIPS score in 2017
• The "pick your pace" option in 2017 allows a physician to avoid a negative payment adjustment by "testing" the program; for example, reporting one quality measure on one patient
• Physicians do not have to participate in the ACI component of MIPS in 2017, but they can at their own discretion. The "test" option for ACI in 2017 is to complete the ACI Base Score measures (see page 4 of this ACI fact sheet).
• There is a 90-day reporting period for ACI in 2017 and 2018

Medicaid EHR incentive program

• Medicaid-eligible physicians have the option of participating in Modified Stage 2 or Stage 3 MU measures in 2017
• Medicaid-eligible physicians must meet one of the following:
  • Have a minimum 30 percent Medicaid patient volume
  • Be a pediatrician and have a minimum 20 percent Medicaid patient volume
  • Practice predominantly in a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) and have a minimum 30 percent patient volume attributable to needy individuals

• Medicaid-eligible physicians may receive up to $63,750 in incentive payments over the life of the program.
• Medicaid-eligible physicians are not subject to Medicaid MU penalties.
• There are 90-day reporting periods for Medicaid MU in 2017 and 2018.

Medicare-eligible hospitals and critical-access hospitals

• All Medicare-eligible, hospital-based physicians are required to attest to a single set of measures
  • Eligible hospitals decide which MU program to participate in—Modified Stage 2 or Stage 3
• Hospital-based physicians perform 90 percent or more of their services in an inpatient hospital or emergency room hospital setting
• There are no Meaningful Use incentives available to hospital-based physicians; eligible hospitals receive incentives directly
• There are no Meaningful Use penalties for hospital-based physicians; eligible hospitals are subject to penalties directly
• There are 90-day reporting periods for Medicare Meaningful Use hospitals in 2017 and 2018

The AMA Opioid Task Force this week released an updated guidance document for physicians and other health professionals to encourage them to co-prescribe naloxone when clinically appropriate.

The updated resource (PDF) recommends that physicians consider several key questions that the task force believes can be helpful when determining whether to co-prescribe naloxone to a patient, or to a family member or close friend of the patient:

• Is the patient receiving a high dose of opioids?
• Does the patient also have a prescription for a benzodiazepine?
• Does the patient have a history of substance use disorder?
• Does the patient have an underlying mental health or other medical condition that makes him or her more susceptible to overdose?
• Would the patient be in a position to help another person at risk of overdose?

"If it were not for naloxone, it is likely that many thousands more would be dead from an opioid-related overdose," said Patrice A. Harris, MD, MA, AMA Opioid Task Force Chair. "We know that naloxone—by itself—will not reverse the nation's opioid epidemic, but it is a critical component that saves lives and provides a second chance."

The updated guidance document, as well as the AMA opioid microsite, also includes links to multiple resources for physicians to use in their practice—ranging from recommendations for use in different settings, best practices and product comparisons.

Learn more about the Opioid Task Force and its recommendations to end the nation's opioid epidemic.

The Providers' Clinical Support System for Opioid Therapies (PCSS-O) and the Providers' Clinical Support System for Medication Assisted Treatment (PCSS-MAT) recently released several new free resources for primary care physicians and other prescribers in the prevention, identification and treatment of opioid-use disorders (OUD) and co-occurring mental disorders. The Substance Abuse and Mental Health Services Administration-funded projects are led by the American Academy of Addiction Psychiatry and a coalition of many national professional organizations, including the AMA.

PCSS-O recently launched its 14-module core curriculum on pain for primary care physicians and other prescribers who want in-depth, evidence-based knowledge in preventing and treating chronic pain and OUD.

PCSS-MAT clinical experts recently created a series of naltrexone online modules on evidence-based approaches to prescribing naltrexone for the treatment of OUD. Naltrexone is one of three medications approved by FDA for treating OUD.

In addition to webinars and courses (most with CME and CEU), PCSS offers clinicians the unique opportunity to connect with a network of national experts in the fields of pain management and substance use disorders. PCSS-O and PCSS-MAT clinical experts provide support via email, telephone, or in person when viable. PCSS also offers a discussion forum in which clinicians may ask a clinical question and have that question answered by the "Expert of the Month."

Learn more about the free resources now available from PCSS.

• Aug. 24, 2017: Advocacy spotlight on QPP rule should be simpler, more flexible 
• Aug. 24, 2017: State Advocacy Update 
• Aug. 24, 2017: Judicial Advocacy Update