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In an August 9 proposed regulation, the Centers for Medicare & Medicaid Services (CMS) seeks to overhaul the Medicare Shared Savings Program and encourage Accountable Care Organizations (ACOs) to transition from one-sided models to two-sided models with increasing financial risk. The CAP is evaluating several aspects of the proposed regulation and will engage with the CMS on recommendations concerning pathologists.

To accomplish the goal of encouraging ACOs to take on increased risk, the CMS is redesigning the Medicare Shared Savings Program – now called “Pathways to Success” – to include two tracks, Basic and Enhanced, starting on July 1, 2019.

The Basic track allows ACOs to begin under a one-sided model and transition to greater risk under a “glide path.” Eligible ACOs in the Basic track would only be able to participate in a one-sided model for the first two years. The Enhanced track is based on the program’s existing Track 3. The CAP supports the voluntary development of innovative health care payment and delivery models – including ACOs – and is evaluating the impact of these policy changes on the pathologists’ ability to meaningfully participate in and effectively contribute to these models’ success.

In addition to the redesigned tracks, changes in the proposed regulation that may impact pathologists include:

  • Risk Adjustment – The CAP believes ACO incentive compensation must be risk-adjusted for the patient population served.
  • Electronic Access to Patients’ Health or Medical Records – The CMS is proposing a number of changes related to electronic health record (EHR) and Certified Electronic Health Record Technology (CEHRT) participation. The CAP encourages that the proposed CMS guidelines for ACOs have a bi-directional exchange of data between the laboratory and other patient information. Pathologists need to be provided with electronic access to the patients’ health or medical records in a compatible format that is uniform with other participating physicians in the ACO.
  • Benchmarking Length of ACO Participation Agreements – The CMS is proposing to increase participation agreements from three to five years, in order to “provide ACOs with greater predictability on their cost targets and reduce the burden associated with moving into a new agreement.”

The CAP will continue to engage with the CMS to ensure pathologists’ ability to participate in ACOs and other alternative payment models and will submit recommendations by an October 16 deadline.

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As the National Institutes of Health (NIH) All of Us Research Program gets underway, the CAP is concerned that the guidelines to collect these specimens from the cohort of 1 million study subjects need to be examined. The CAP is encouraging the program to have clear and precise requirements for the collection and processing of the biospecimens, according to an August 2 letter sent to the All of Us Research Program.

The All of Us Research Program is part of the Precision Medicine Initiative and will be a public resource full of data so researchers can access the science and medical breakthroughs much faster and easier. The data collected can be used by any researcher around the world, as long as they follow strict privacy and security rules.

In a letter dated February 23, 2018, the CAP encouraged the NIH to “establish requirements for the collection and processing of the biospecimens, as the lack of best practice guidelines for personnel and biospecimen collection, may result in poor quality biospecimens which, in turn, will jeopardize the goals of the Program.”

The CAP proposed recommendations for the collection and processing of blood and tissue specimens stating that “the compliance with these data-driven practice metrics is a first and essential step towards achieving a quality continuum for patient biospecimens.” The CAP further states that a pathologist’s input on biospecimen issues is both appropriate and important and encourages the opportunity to incorporate specimen pre-analytic standards in the All of Us research program.

To learn more about the program, including what it means to be a participant, visit

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Based on feedback from various clinicians and groups, the CMS updated the Quality Payment Program (QPP) website so that the 2017 Merit-based Incentive Payment System (MIPS) payment adjustment and additional adjustments for exceptional performance are now displayed separately.

The CMS originally displayed a single payment adjustment amount, which included an additional adjustment for exceptional performance available to MIPS eligible clinicians and groups with a final score of 70 or greater. The updated system will display the total MIPS payment adjustment, which is the sum of the MIPS performance and exceptional performance.

You can access your 2017 MIPS performance feedback and final score by:

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Take our Readership Survey and Win an Apple Watch

The CAP invites readers to take a quick survey regarding STATLINE, our weekly federal and state advocacy e-newsletter. STATLINE strives to keep CAP members updated on the latest regulatory and legislative issues concerning pathologists at the federal and state levels of government. Through news briefs, STATLINE provides clarity on these issues while also reporting what the CAP is doing to address matters concerning pathologists. Your valuable feedback will allow us to evaluate and improve the e-newsletter to best meet your needs. This survey should take about 3-5 minutes to complete.


The CAP recognizes the value of your time and privacy. Be assured that your individual information will be kept strictly confidential and your email address will not be distributed to anyone. All results are reported in aggregate format. If you need assistance, please email Lori Vernon at LVERNON@CAP.ORG.

As a thank you for your time and feedback, we invite you to enter into a drawing to win one Apple Watch. If you would like to enter, please enter your information at the end of the study.

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First webinar recording available

Navigating all the requirements related to successfully complying with MIPS can be confusing; especially for non-patient-facing physicians such as pathologists. And on top of that, you may be at risk for losing bonus opportunities if you don’t fully optimize your participation.

As part of our ongoing commitment to ensure pathologists are able to successfully participate in new and evolving payment models, the CAP offered its first MIPS educational webinar on August 2 on how to Maximize Your MIPS Bonus Potential, led by Diana Cardona, MD, FCAP, Chair of the Economic Affairs Measures & Performance Assessment Subcommittee.

Emily E. Volk, MD, FCAP

The second in this webinar series – MIPS Reporting: Which Path is Right for Your Practice? – will take place on Thursday, September 6 at 11 AM ET/ 11 AM CT. During this 30-minute webinar, Emily E. Volk, MD, MBA, FCAP, Vice-Chair of the Council on Government and Professional Affairs and Chair of the CAP Clinical Data Registry Ad-Hoc Committee, will explore the MIPS readiness checklist and learn how to choose the best reporting options for your practice. Register today.

Other upcoming webinars in the MIPS series are open for registration:

Pathologist Improvement Activities Under MIPS
Tuesday, September 20, 2018, 1 PM ET
Diana Cardona, MD, FCAP
Explore the MIPS readiness checklist and learn how to choose the best reporting options for your practice.

2019 Final Medicare Policy and Payment Changes
W Stephen Black-Schaffer MD, FCAP
Donald S. Karcher, MD, FCAP
Emily Volk, MD, MBA, FCAP
Details coming soon.

Quality Measures that Will Improve Your MIPS Score
Tuesday, December 4, 2018, Noon ET
Diana Cardona, MD, FCAP
Examine ways of improving your performance and MIPS scores using CAP-developed quality measures.

Steps to Take Before Reporting MIPS Data
Tuesday, January 8, 2019, 3PM ET
Emily Volk, MD, MBA, FCAP
Discover ways of maximizing your scoring for 2018 before submitting results to CMS.

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STATLINE will take a scheduled break on August 21. You will receive the next edition of STATLINE in your email inbox on August 28. Please continue to check the CAP TWITTER, FACEBOOK, and CAPCONNECT accounts for updates from the CAP.

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