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The Medicare program should offer incentives only to its administrative contractors for truly exceptional performance that is measurable and transparent to physicians and other stakeholders, the CAP recommended in a February 19 letter to the Centers for Medicare & Medicaid Services (CMS).

The CAP responded to a Request for Information from the agency as it seeks opinions from the public on ways to incentivize and reward exceptional Medicare Administrative Contractor (MAC) performance. The CAP offered in its comment letter specific performance standards that it hopes will enable the CMS to identify potential adjustments in the terms and conditions of MAC contracts for the purpose of improving Medicare's administrative services to beneficiaries and health care providers.

Further, the CAP's comments support its advocacy to strengthen transparency and the appeals process for Medicare LCD development by MACs. The CAP is seeking the introduction of legislation in Congress to reform the LCD process, with the goal to ensure that coverage decisions are made by qualified health experts through a transparent process and based on sound medical evidence.

For example, the CMS should consider adopting additional performance metrics for the local coverage determination (LCD) advisory and development process, gapfill process for setting reimbursements, and physician assessment of MACs. Contract extensions also should be granted to MACs only after rigorous performance assessment is conducted and exceptional performance is demonstrated, the CAP said. Incentives in the form of contract extensions would be in the form of up to five, one-year options for renewal of an initial five-year contract, amounting to a maximum duration of 10 years contingent upon annual assessments and continuous attainment of exceptional performance by the MAC. Under no circumstance would contracts afford an automatic renewal.

The CMS depends on a group of 12 MACs to handle more than 4.9 million Medicare claims on an average business day. Around $365 billion is disbursed as program payments by MACs each year. Additionally, MACs are responsible for other major tasks like processing Medicare claims, monitoring the enrolments in the Medicare programs, answering inquiries from healthcare providers and suppliers, and providing outreach and education services to healthcare providers and suppliers.

Read the CAP's full comments on MACs to the CMS.

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The CAP will host a panel discussion on the oversight of laboratory-developed tests (LDTs) during its 2016 CAP Policy Meeting May 2-4, in Washington, DC.

The panel discussion will review the issue with Alberto Gutierrez, PhD, Director of the Food and Drug Administration (FDA) Office of In Vitro Diagnostics in the Radiological Health Center for Devices and Radiological Health. The FDA has drafted guidance on providing oversight of LDTs and it's expected to finalize the guidance this year.

Under the FDA's draft guidance, the FDA would continue enforcement discretion for certain low-risk LDTs. It also would implement a risk-based, phased-in approach for oversight of high-risk and moderate-risk LDTs. The CAP has advocated for a different approach, and put forth in a legislative proposal, which would allow for continued test innovation and would not overburden laboratories.

Attend the 2016 Policy Meeting to hear from policy experts and take action to advocate on behalf of the pathology specialty. On May 4, pathologists will meet with their senators and representatives in Congress during the CAP's annual Hill Day.

Collaborate. Advocate. Take Action.

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. The CAP's Annual Hill Day will take place on May 4.

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The Centers for Medicare & Medicaid Services (CMS) extended its submission date for 2015 Quality Reporting Document Architecture (QRDA) data submission for the Electronic Health Record (EHR) reporting mechanism to March 11, 2016, for individual eligible professionals, Physician Quality Reporting System (PQRS) group practices, Qualified Clinical Data Registries (QCDRs), and qualified EHR data submission vendors.

Eligible physicians and other providers who do not satisfactorily report quality measure data to meet the 2015 PQRS requirements will be subject to a negative PQRS payment adjustment on all Medicare Part B Physician Fee Schedule services rendered in 2017.

Submission ends at 8 pm ET on the end date listed:

  • Electronic Health Record Direct or Data Submission Vendor (QRDA I or III) – March 11
  • Qualified Clinical Data Registries (QCDRs) (QRDA III) – March 11
  • Group Practice Reporting Option Web Interface – March 11
  • Qualified Registries (Registry XML) – March 31
  • QCDRs (QCDR XML) – March 31

An Enterprise Identity Management (EIDM) account with the "Submitter Role" is required for these PQRS data submission methods. See the EIDM System Toolkit for additional information.

For questions, contact the QualityNet Help Desk at 866-288-8912 or from 7 am to 7 pm CT. For complete information, visit the CMS' PQRS website.

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Beginning July 20, freeze sprays containing HFC-134a, a type of aerosol propellant, will no longer be allowed to be manufactured. While products manufactured prior to that date may still be used after July 20, pathologists will eventually need to switch to alternative freeze sprays.

The changes are required by a final rule issued by the Environmental Protection Agency (EPA) last July 20, which changes the listing status of certain hydrochlorofluorocarbons (HFCs) from acceptable to unacceptable.

There is concern about the viability of new products to replace sprays currently used for freezing human tissue. The CAP has heard from some pathologists who are concerned about the availability of alternative freeze sprays that would be acceptable under the regulation. The CAP is engaged on this issue and will provide additional updates through STATLINE as information becomes available.

Under the Significant New Alternatives Policy (SNAP) rule, HFC-134a, HFC-227a and blends of the two compounds cannot be used as an aerosol propellant as of July 20, 2016. There are some medical device exceptions to the HFC-134a ban, but it does not appear that freeze sprays used in pathology are exempt. Topical coolant sprays for pain relief and products for wound care sprays containing HFC-134a will continue to be allowed until December 31, 2017.

HFCs were initially designed to replace chlorofluorocarbons (CFCs), which were phased out due to their effect on ozone depletion in the upper atmosphere. However, according to the EPA, HFCs are potent greenhouse gases (GHGs) much like the ozone-depleting substances they replace. Although they represent a small fraction of the current total volume of GHC emissions, their warming impact is very strong. The mostly commonly used HFC is HFC-134a, which is 1,430 times more damaging to the climate system than carbon dioxide.

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