News and noteworthy information for June 2016:
- ISASS Convenes Payment Models Subcommittee
- ISASS Submits Comments to MACRA/Quality Payment Program Proposed Rule
- ISASS Submits Comments to 2017 Hospital Inpatient Proposed Rule
- CPT® Summary of Panel Actions Posted from May 2016 Meeting
- Recap of the AMA House of Delegates Annual Meeting
- Comprehensive Medicare Coverage of Minimally Invasive Sacroiliac Joint Fusion Surgery
- GAO Makes MedPAC Appointments
ISASS Convenes Payment Models Subcommittee
In order to enhance the Society’s advocacy work, last month, ISASS convened a new subcommittee of the Coding & Reimbursement Task Force. The Payment Models Subcommittee is being spearheaded by Isador Lieberman, MD, Morgan Lorio, MD, Kern Singh, MD, and Cindy Vandenbosch and was formed to:
- review regulatory changes and submit comments to rulemakings that inform and shape the payment landscape for spine surgery going forward;
- educate the U.S.-based ISASS membership on payment and quality reporting changes coming down the pipeline from Congress and the Centers for Medicare and Medicaid Services (CMS); and
- analyze and develop new physician-focused, voluntary alternative payment models that work for spine surgery.
The Subcommittee’s first projects include reviewing the proposed spine fusion episode-based payment measure in the 2017 hospital inpatient proposed rule and reviewing the MACRA/Quality Payment Program proposed rule in order to provide meaningful feedback to CMS. If you are interested in serving on the Payment Models Subcommittee or the Coding & Reimbursement Task Force, please contact Liz Vogt (firstname.lastname@example.org).
ISASS Submits Comments to MACRA/Quality Payment Program Proposed Rule
The Medicare Access & CHIP Reauthorization Act of 2015 (MACRA) was bipartisan legislation signed into law in April 2015 to permanently repeal the Sustainable Growth Rate (SGR), streamline physician quality reporting programs, and provide incentive payments for physician participation in alternative payment models. MACRA sunsets the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier, and the Medicare Electronic Health Record (EHR) Incentive Program in 2018 and establishes an umbrella Quality Payment Program with two new pathways for payment: 1. Merit-Based Incentive Payment System (MIPS) and 2. Advanced Alternative Payment Models (Advanced APMs).
In April 2016, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule to begin the process of implementing MACRA. The proposed rule establishes a framework for the Quality Payment Program including details on the two new tracks for payment: MIPS and APMs.
ISASS submitted comments to CMS on issues identified in the proposed rule as well as suggestions to improve the Program’s framework. A copy of the ISASS letter can be found here. A final rule is expected to be released by November 1, 2016. For more information on MACRA and the Quality Payment Program, visit the MACRA resource page on the ISASS website.
ISASS Submits Comments to 2017 Hospital Inpatient Proposed Rule
On April 18, the Centers for Medicare and Medicaid Services (CMS) released the proposed 2017 Hospital Inpatient and Long-Term Care Hospital (LTCH) payment and policy rule. The proposed rule, which would apply to approximately 3,330 acute care hospitals and approximately 430 LTCHs, would affect discharges occurring on or after October 1, 2016. (Please note physician payment is made via the Physician Fee Schedule, which will be released in July.)
The Hospital Inpatient Prospective Payment System (IPPS) pays hospitals for services provided to Medicare beneficiaries using a national base payment rate, adjusted for a number of factors that affect hospitals’ costs, including the patient’s condition and the cost of hospital labor in the hospital’s geographic area. CMS generally sets payment rates prospectively for inpatient stays based on the patient’s diagnosis and severity of illness. A hospital receives a single payment for the case based on the payment classification (MS-DRGs under the IPPS) assigned at discharge.
The following provisions relate to hospital payment and policy for inpatient spine surgery:
- The SFusion Payment Measure
- Reassignment of Decompression Laminectomy Codes
- Removal of Lordosis Codes from Secondary Diagnosis List
- Evaluation of New Technology Add-On Payments
- Addition of Reposition Codes to MDC 8 in MS-DRGs 515, 516, and 517
A more detailed summary including provisions related to spine surgery can be found here. ISASS submitted comments to CMS regarding the proposed SFusion payment measure. A copy of the ISASS letter can be found here. The final rule is expected to be released by August 1, 2016.
CPT Summary of Panel Actions Posted from May 2016 Meeting
On June 10, the American Medical Association posted the CPT® Editorial Summary of Panel Actions, a high-level summary of the final actions taken by the CPT® Editorial Panel at the May 2016 meeting in Chicago. Note that in the 2017 code set, CPT® 22305 (closed treatment of vertebral process facture) will be deleted. The next CPT® Editorial Panel meeting will take place September 29-October 1 in Austin, TX.
Recap of the AMA House of Delegates Annual Meeting
The AMA House of Delegates annual meeting was held in Chicago on June 11-15. After a three-year process to obtain a voting seat, ISASS became a voting member of the AMA’s House of Delegates (HOD) in June 2014. The HOD is the legislative and policy-making body of the AMA and includes over 500 voting delegates selected by their member organizations to establish broad policy on health, medical, professional and AMA governance issues. Members of the HOD include state medical associations, the five federal services, national medical specialty societies and professional interest medical associations, sections and groups. ISASS is considered a national medical specialty society in the HOD and participates in the Specialty and Service Society (SSS) Caucus, the largest caucus in the HOD. Gunnar B.J. Andersson, MD, PhD serves as the ISASS delegate to the HOD and Morgan Lorio, MD, FACS serves as the ISASS alternate delegate to the HOD.
The overarching themes of this year’s annual meeting included opioids, gun violence, MACRA, simplifying regulatory burdens, and activating physicians as advocates. During the opening session of the HOD, AMA President, Dr. Steven Stack gave an impassioned speech (speech available here: http://www.ama-assn.org/ama/ama-wire/post/bright-future-horizon-path-there) on the joy and frustration that physicians experience daily, protecting the physician/patient relationship, being solution-oriented, and persevering in the face of seemingly insurmountable challenges. CMS Acting Administrator, Andy Slavitt, also addressed (speech available here: https://blog.cms.gov/2016/06/13/remarks-by-andy-slavitt-cms-acting-administrator-before-the-american-medical-association-2016-annual-meeting-chicago-il/) the House and spoke about CMS’ quest to engage with the physician community and simplify reporting burdens while ensuring high-quality, cost-effective care for Medicare beneficiaries.
Dr. David Barbe was elected as President-elect of the AMA, his term beginning in June 2017. Dr. Susan Bailey was reelected as Speaker of the House and Dr. Bruce Scott was reelected as Vice Speaker of the House. Dr. Willarda Edwards and Dr. William Kobler were elected to the AMA Board of Trustees.
This year, over 200 reports and resolutions were introduced for consideration by the HOD, however not all introduced resolutions were adopted as policy. The HOD can vote to adopt resolutions, amend resolutions, refer resolutions to the Board of Trustees for further study or for decision, or choose not adopt certain resolutions. Some of the hot-button issues at this year’s meeting included:
- Modernizing the code of medical ethics, the first comprehensive update in more than 50 years
- Establishing new ethical rules for use of telehealth and telemedicine
- Supporting methods to identify and correct lead contamination in public drinking water supplies
- Calling on Congress to provide immediate funding for Zika research and prevention
- Encouraging the development of physician-led alternative payment models that reduce regulatory burdens and increase technical assistance to help practices implement the models
- Deeming gun violence a “public health crisis” requiring a comprehensive public health response including legalizing CDC research on gun violence and calling for mandatory background checks and waiting periods for all firearm purchases
- Supporting mandatory medication take-back programs funded by pharmaceutical manufacturers
- Supporting policies that provide paid sick leave
- Including physician wellness/work-life balance in as a fourth element of the Triple Aim
- Exploring and reporting on potential funding sources and mechanisms to pay for physician time and expense pursing prior authorization of procedures/treatments
The interim meeting of the House of Delegates will be November 12-15 in Orlando, FL.
Comprehensive Medicare Coverage of Minimally Invasive Sacroiliac Joint Fusion Surgery
On June 17, First Coast Service Options, the Medicare Administrative Contractor covering the state of Florida, issued a Medical Review Article that removes CPT® 27279 (Arthrodesis, sacroiliac joint, percutaneous or minimally invasive (indirect visualization), with image guidance, includes obtaining bone graft when performed, and placement of transfixing device) from its non-covered services policy. The Medical Review Article states that there is “no current LCD given there is a paucity of evidence to establish medical necessity for the general Medicare population. However, due to the common nature of this problem, the contractor will be providing access to coverage for CPT code 27279. It will be considered for coverage on a case-by-case basis for the treatment of chronic back pain for certain patients, assuming all other applicable program requirements are met.” The Medical Review Article goes on to list the patient criteria that will be considered by medical reviewers in making clinical judgments if a prepayment or post-payment audit is implemented. This announcement means that all Medicare beneficiaries now have access to coverage for minimally invasive sacroiliac joint fusion surgery, regardless of state or Medicare jurisdiction.
GAO Makes MedPAC Appointments
On June 2, the U.S. Government Accountability Office (GAO) announced the appointment of five new members to the Medicare Payment Advisory Commission (MedPAC) and the reappointment of one current member. MedPAC is an independent agency of Congress whose mandate is to analyze access to care, quality of care, and other issues affecting Medicare and to advise Congress on payments to health plans participating in the Medicare Advantage program and providers in Medicare’s traditional fee-for-service program. MedPAC was established by the Balanced Budget Act of 1997. There are 17 Commissioners who serve part-time appointed to three-year terms (subject to renewal) by the Comptroller General. Appointments are staggered; the terms of five or six Commissioners expire each year.
The newly appointed members are:
- Amy Bricker, RPh, Vice President, Supply Chain Strategy, Express Scripts, Inc., St. Louis, MO
- Brian DeBusk, PhD, CEO, DeRoyal Industries, Powell, TN
- Paul Ginsburg, PhD, Leonard Schaeffer Chair in Health Policy Studies, Brookings Institution, Washington, D.C. and Professor of Health Policy, University of Southern California
- Bruce Pyenson, FSA, MAAA, Principal and Consulting Actuary, Milliman, Inc., New York, NY
- Pat Wang, JD, CEO, Healthfirst, New York, NY
The appointees’ terms will expire in April 2019. The reappointed member, whose term will also expire in April 2019, is Jon Christianson, PhD, Professor of Health Policy and Management at the University of Minnesota’s School of Public Health, Minneapolis, MN. He will continue to serve as Vice Chair.