By Stephanie Farnia, ASBMT Director of Health Policy and Strategic Relations
Medicare Inpatient Payment Rule
I’ll start this month’s column with a resounding THANK YOU to all of you that took the time to really understand the issues with the CMS FY18 Inpatient Prospective Payment System (IPPS) Proposed Rule. More than 44 transplant centers (TC) commented with a total of 138 TC comments. The highest volume TCs were Dana Farber, University of Kentucky and University of North Carolina.
The ASBMT comment letter can be found here. For those of you that have not read it yet, I would encourage you to do so even though it may seem daunting and framed in “CMS-ease.” While it is undeniably a letter that is technical in nature, it is intended to also be accessible to most individuals reasonably familiar with transplant and cellular therapy. And to be quite honest – it’s supposed to make logical sense to anyone who picks it up, regardless of background in CMS systems. [I often subject my motor-design-engineer husband to a final proofread and he made it through this one without wandering off to “go fix something” – a positive sign.]
I ask you to spend a little more time than usual with this year’s comment letter because there almost definitely be significant long-term financial impact because of it – the proposed changes to how autologous and allogeneic HCT are categorized/paid, the proposed New Technology Add-on Payment for CAR T, the lack of a proposal to pay separately for allogeneic HCT donor acquisition costs are a few key examples. These issues will likely not be fully resolved by the time of the issuance of the final rule in August and the more understanding you have of the issues your programs will face in the next few years, the better.
Call for Volunteers – ASBMT Legislative Day in Washington, DC
This has been a year of tremendous upheaval in the health policy area – changes to Medicare, Medicaid, the Affordable Care Act, and the NIH budget have all been near-constant topics of conversation. This climate has underscored the need for ASBMT to have an active core set of volunteers willing to interact with their legislators about important issues that will potentially affect the field and/or the patients you all serve. ASBMT will be holding its first stand-alone Legislative Day in Washington, D.C. on Thursday, September 7. The goal for the day will be to educate Congressional representatives on issues that affect the field of HCT – Medicare coverage and reimbursement, physician payment and research funding. If you are interested in potentially attending, please email me at StephanieFarnia@asbmt.org. No experience necessary! There will be a pre-arrival training via conference call and an in-depth session the morning of our Hill visits. All ‘newbies’ will be paired with a more experienced attendee for the day and ASBMT will pay costs for selected attendees.
We will be choosing a group of approximately 10-15 individuals based on home locations that represent key Congressional or Senate districts – but everyone who is interested should please feel free to send me a note. We will be interacting with Congress in many ways during the upcoming year and will likely have several other opportunities to integrate volunteers.
CMS Quality Payment Program – Year 2 Proposed Rule
On June 20, CMS released the proposed rule for the Quality Payment Program (QPP). QPP is the part of the MACRA legislation that modifies how CMS pays physicians and creates requirements and incentives meant to encourage value-based reimbursement models. If you need a reminder about QPP, click here to read ASBMT’s June 2016 response to CMS’s Proposed Rule on MACRA.
While the initial information about the program was developed and released over the last two years, many technical details and methodologies that will be used to calculate physician responsibility and payments are still in development. Many large physician organizations, including the ACP and the AMA have raised significant concerns about the burden, accuracy and cost associated with QPP – particularly for the qualified providers that are within small or solo practices.
The Proposed Rule does not fix all the concerns raised, but it does propose to change the eligibility threshold that delineates providers as being subject to or excluded from the new requirements. The previous language read that all providers with more than $30,000 in Medicare Part B bills associated with at least 100 Medicare beneficiaries in the measurement year would be subject to the changes. The proposed rule has modified those thresholds to $90,000 and 200 Medicare beneficiaries – changes that modify the eligibility status of hundreds of thousands of providers according to early analyses. All of you that fall into the categories of clinicians initially affected by the QPP (MD, PA, NP) should have received a letter regarding your personal status for the program sometime in May or June. If you do not remember receiving the letter or used it as a coaster on your desk one time too often, you can check your status with your NPI number here: www.qpp.cms.gov. I would recommend reviewing your status in light of the proposed changes to the eligibility thresholds, as some of you may no longer be subject to QPP if the proposed changes are made final.
Please note: these modifications do not mean that CMS is moving away from a focus on outcomes-based payment. I fully expect that we will continue to see new Alternative Payment Models and other value-based payment initiatives be proposed over the next months and years. The QPP Proposed Rule comment period closes on August 21 and comments can be submitted via www.regulations.gov (search for “Quality Payment Program” or CMS-5522-P). The full rule is available here and a lengthy Fact Sheet is available as well. All of the major healthcare organizations will be busily digesting the rule and sharing their perspectives with constituents over the next two weeks so keep an eye out for advocacy/legislative alerts on the topic.
Finally, I want to recognize the efforts of Dr. James Gajewski for his role in making these important new cost-based measures more realistic for all you that will be utilizing them. Dr. Gajewski was asked to participate in the initial development of the methodology that will be used to identify and benchmark pulmonology care episodes for the purposes of QPP measurement. It has been a long, tedious and very technical project but it has been very useful in pro-actively identifying issues we will need to focus on when CMS moves into doing this same work for HCT and other Hematology/Oncology care.
Until next time!
Stephanie
@HCT_Policy
Read the entire July 2017 ASBMT eNews here.