STATLINE

Read the Latest Issue of STATLINE

In This Issue:

• Which Medicare Quality Reporting Options Fit Your Pathology Practice?
• Earn 8.25 CME Credits at the 2016 CAP Policy Meeting
• Your Last Chance to Receive Early Access to the Practice Leader Survey Results
• House Lawmakers Want Delay in Implementation of New Lab Payment System
• Minnesota Lawmakers Accept CAP Amendment to Genetic Counselor Bill

Access the CAP's online tool to determine how your practice can participate in the 2016 Physician Quality Reporting System (PQRS) and learn how to avoid Medicare reimbursement penalties from PQRS and the Value-Based Modifier (VBM) program.

Pathologists are at risk of having Medicare payments reduced when the Centers for Medicare & Medicaid Services (CMS) determines that they could have participated in PQRS and did not. Performance on PQRS measures in 2016 will be the factor deciding whether their Medicare Part B payments will have a negative PQRS and VBM adjustment in 2018.

To use the CAP PQRS/VBM tool, you select choices on how to participate in the PQRS. Answer selections will depend on the size and type of your practice. The tool will help guide your decisions to determine eligibility and includes a frequently asked questions section at the end.

While the CMS has stated that the penalties will not apply for pathologists who have no applicable PQRS measures, the CMS plans to review claims to check that none of the measures applied. Eligible physicians face a 2% penalty in 2018 for not successfully reporting PQRS measures in 2016. PQRS is a factor in the VBM, which also could penalize eligible physicians by an additional 2% to 4% in 2018 following the 2016 PQRS reporting year.

The CMS plans to finalize how the 2018 VBM will be applied, including bonus calculations, to all physician and non-physician eligible providers in a future rulemaking. For 2016, the CMS published a fact sheet in September 2015 showing how penalties and bonuses were calculated for this year.

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By registering and participating in the 2016 CAP Policy Meeting May 2-4, you will be eligible to earn 8.25 continuing medical education (CME) credits.

During the CAP Policy Meeting, attendees will receive the latest information and analysis on the implementation of new Medicare and laboratory regulations. The Policy Meeting in Washington, DC also will include meetings with members of Congress and their staff during the CAP’s Annual Hill Day on May 4, which is the specialty's opportunity to focus on the federal issues most important to pathologists now and in the future.

Register for the meeting today. The CAP Policy Meeting is a benefit of CAP Membership. There is no fee to register.

The CAP is accredited by the Accreditation Council for Continuing Medical Education (ACCME) to provide CME for physicians.

The CAP designates this live educational activity for a maximum of 8.25 AMA PRA Category 1 Credit(s)™. Physicians should claim only credit commensurate with the extent of their participation in the activity.

At the end of the Policy Meeting, participants should be able to:

• Identify current issues in the field with a focus on practical issues for pathology (eg, payment challenges, new delivery models, pay-for-performance, clinical laboratory fee schedule changes, other laboratory regulations)
• Identify emerging practice delivery models and payment models
• Discuss the impact of health care reform implementation and permanent changes on pathologists and laboratory medicine
• Prepare and effectively communicate messages in a manner that advocates for pathology
• Implement the tools needed (eg, direct engagement, use of social media and storytelling) to be an effective advocate for your profession

Join your colleagues at the 2016 CAP Policy Meeting in Washington, DC. Focus on the issues most important to pathologists now and in the future.

Collaborate. Advocate. Take Action.

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Time is running out to complete the 2016 Practice Leader Survey and participate in the survey gathering data from individual pathology practices regarding their economics, demographics, and market trends. CAP members who complete the survey will receive an invitation to an exclusive webinar reviewing the results and be entered in a contest to win prizes.

Data from the new survey will help CAP leaders determine which advocacy issues are most important to pathology practices and further assist the CAP on advocating on behalf of the pathology specialty. The survey, which practice leaders receive an emailed invitation to take, is targeted to those who can answer the questions for the whole practice. For some practices this will be one individual, while for others it will be multiple individuals.

Practices with more than one practice leader should coordinate about how to best complete one survey for their practice. For a listing of the specific questions on the survey, please email practicesurvey@cap.org.

All responses are kept strictly confidential. Responses will be reported in aggregate form only. No individual practice information will be uniquely identified or shared.

Reminders Emailed to Practices on April 5

Pathology practice leaders began receiving invitations to complete the survey on March 21 and reminders were sent on April 5. CAP members who complete the survey, which should take about 20 minutes to complete, will later receive an invitation to attend an exclusive webinar reviewing the survey results. A report on the survey will then be available for all CAP members.

Those completing the survey will receive early access to the results. The CAP will publish more details about this and other benefits for completing the survey.

Learn more about the 2016 Practice Leader Survey.

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A bipartisan group of House lawmakers is calling on the Centers for Medicare & Medicaid Services (CMS) to delay changes to the new Medicare payment system for clinical laboratory tests, noting that the CMS has missed almost every regulatory deadline for implementation mandated by law.

Health Subcommittee Chair Pat Tiberi (R-OH) and Reps. Patrick Meehan (R-PA) and Bill Pascrell (D-NJ), along with 23 members of the Ways and Means Committee, on March 29 sent a letter to the acting administrator of the CMS urging a delay in implementation of the new payment system.

This letter follows a similar request submitted to the CMS in December by a group of House and Senate lawmakers (including some of whom have signed on to the March 29 letter).

"Updating the [Clinical Laboratory Fee Schedule] is a highly complex task with significant implications for all stakeholders, with a reach far beyond the Medicare program," the March 29 letter said. "We believe the critical alterations to the CLFS must be accomplished in a deliberate and measured manner, so that laboratories have sufficient time, once the final rule and subregulatory guidance are issued, to comply. Given the delays in the rulemaking process, the January 1, 2017, effective date for the new CLFS payment methodology is not feasible and should be delayed."

The CMS has already missed critical deadlines, the lawmakers note. The Protecting Access to Medicare Act (PAMA), which mandated the new payment system, required that a proposed rule be issued by June 30, 2015, followed by a final rule prior to January 1, 2016. Laboratories initially were supposed to have begun reporting their private payer data to the CMS beginning January 1, 2016 (this was subsequently delayed until March 31, 2016), but without the final rule, such reporting could not begin. The proposed rule was issued September 25, 2015. CMS officials have not indicated when a final rule will be published.

"Obviously, [none of] these deadlines has been met," say the lawmakers. "Congress set up this specific set of milestones to ensure that laboratories and CMS would have sufficient time to collect, report, submit and analyze private payer data and establish new reimbursement rates. We strongly believe this timeframe is necessary to successfully implement market-based reform."

CAP Has Also Called for A Delay

The CAP supports a delay to the collecting and reporting of data and in implementation of the new laboratory payment system. In comments submitted to the CMS November 24, the CAP recommended that the initial reporting period be from January 1, 2016 through June 30, 2016, with reporting of private payer data to the CMS by September 30, 2016. However, this was based on an assumption that by January 2016 the CMS would have defined what specific data is to be reported. Given that no such guidance has been provided as of March 31, the CAP supports a greater delay in both reporting of data and implementation of the new payment system.

"To achieve compliance with reporting requirements, timely and clear guidance on the specifics of applicable information to be reported that reflects private payor contracting and claims/adjustment processes is essential as is both an extension of both the data submission deadline and data collection period," said the CAP in its comments.

The CAP will continue to monitor developments related to the new laboratory payment system and will report on them in future issues of STATLINE.

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A CAP amendment to exempt physicians from licensure requirements for genetic counselors was adopted by Minnesota lawmakers in the Senate during a recent legislative hearing.

The CAP and Minnesota Society of Pathologist (MSP) do not object to the licensure of genetic counselors as defined in the legislation (HF 978/SF 37) but have sought to ensure it did not apply to physicians providing similar services. Elected officials in Minnesota proposed the bill to define the scope of practice of a genetic counselor. If the bill is enacted, practicing genetic counseling without a license would be a misdemeanor offense.

"We believe that this technical amendment will ensure that the practice of medicine is not constrained by a newly codified scope of practice for genetic counselors," the CAP stated in a 2015 letter requesting the amendment.

The bill defines services provided by a licensed genetic counselor to include:

• obtaining and interpreting family and individual medical and developmental historie
• determining inheritance and risk of transmitting genetic conditions
• discussing inheritance, history, diagnosis, and management of conditions with clients
• identifying, ordering, and explaining implications of genetic tests and other studies
• assessing psychosocial factors
• providing counseling and guidance to the client or family
• facilitating informed decision making about tests and management
• identifying and using community resources for medical, educational, financial, and psychosocial support and advocacy
• providing accurate written medical, genetic, and counseling information

The House Health and Human Services Finance Committee scheduled a hearing to discuss the bill on April 5. More news on this issue will be reported in a future issue of STATLINE.

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