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CAP members can access the archived recording of the CAP's November 5 webinar "The 2016 Medicare Physician Fee Schedule's Impact on Pathology Services." During the webinar, CAP experts explained reimbursement and policy changes to pathology services in the 2016 fee schedule recently published on October 30.

The slides for the presentation are also available for download. For more information, read the CAP's STATLINE Special Report on the final 2016 Medicare fee schedule.

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The CAP joined the American Medical Association (AMA), and several specialty and state medical societies to urge Congress to refocus the Electronic Health Record (EHR) Meaningful Use program on improving interoperability and supporting the delivery of high quality health care. A letter sent to Congress follows strong CAP advocacy to prevent pathologists from receiving Medicare penalties under the meaningful use program.

The regulatory framework to measure EHR Meaningful Use has continued to layer requirements "without any real understanding of the way health care is delivered," the groups stated in a November 2 letter to House and Senate (AMA sign in required) leaders. "What has emerged from this morass of regulation is a system that relegates physicians to the role of data entry clerks, filling the patient record with unnecessary documentation requirements unrelated to the provision of quality care."

The CAP also has engaged with Congress and the Centers for Medicare & Medicaid Services (CMS) on the meaningful use program to mitigate potential Medicare penalties. As a result of CAP advocacy, pathologists will receive a hardship exception from Medicare penalties under EHR Meaningful Use program in 2016. In October, the CMS acknowledged specific providers, including pathologists, who will be eligible for hardship exceptions.

Previously, the CAP secured for pathologists an automatic hardship exception in 2015. The CMS is continuing the automatic hardship exception through 2016, which means pathologists won't receive penalties that lower Medicare payments by 1% in 2015 and 2% in 2016.

Most pathologists cannot participate in EHR Meaningful Use. Although the CAP has a minority of members that have successfully attested to Meaningful Use, it is because they are likely part of larger practice organizations, the leaders of whom may be making practice-wide attestations on behalf of all of their physicians, including their pathologists.

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The CMS extended the deadline to download, review, and request corrections to the 2014 Quality and Resource Use Reports (QRURs) and Physician Quality Reporting System (PQRS) Feedback Reports for physicians. The new deadline is now November 23.

The CMS extended the deadline after receiving concerns from the AMA about potential problems with the reports. Physicians are encouraged to review the reports because any errors contained in the reports could negatively affect Medicare reimbursements in 2016.

The 2014 QRURs show how groups and solo practitioners performed in 2014 on the quality and cost measures used to calculate the 2016 value-based modifier. For groups with 10 or more eligible professionals that are subject to the 2016 value modifier, the QRUR shows how the modifier will apply to physician payments under the Medicare Physician Fee Schedule for physicians who bill under the group's tax identifier number (TIN) in 2016.

For all other groups and solo practitioners, the QRUR is for informational purposes only and will not affect their payments under the Medicare PFS in 2016. Authorized representatives of group and solo practitioners can access the 2014 QRURs on the CMS Enterprise Portal using an Enterprise Identify Data Management (EIDM) account with the correct role. For more information on how to access the 2014 QRURs, please read the CMS's guidance on How to Otain a Qrur.

For groups with 10 or more eligible professionals that are subject to the 2016 Value Modifier, the CMS established a 60-day informal review period that begins after the release of the 2014 QRURs, to request a correction of a perceived error in their 2016 value modifier calculation. The informal review period for the 2016 modifier is open from September 9 through November 9. Information about How to Request an Informal Review is available from the CMS.

Groups and solo practitioners are identified in the QRURs by their TIN. The QRURs are also available for groups and solo practitioners that participated in the Medicare Shared Savings Program, the Pioneer Accountable Care Organization (ACO) Model, or the Comprehensive Primary Care initiative in 2014, in addition to those TINs consisting only of non-physician eligible professional.

CAP Quality Measures Available for Public Comment

The CAP is inviting stakeholders to provide comments on draft quality measures for pathologists through a short survey. Your comments are important as CAP leaders work to ensure pathologists can participate in Medicare value-based initiatives.

The CAP convened its Measures & Performance Assessment (M&PA) Subcommittee to assess opportunities for the development of evidence-based performance measures for pathologists. The CAP M&PA Subcommittee, which is part of the CAP Economic Affairs Committee, proposes these measures to promote the highest quality of care.

Please submit your comments here.

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The Health and Human Services Office of Inspector General (HHS OIG) will scrutinize reimbursements paid for Medicare clinical laboratory tests in 2014 and detail findings in a report due in 2016.

Clinical laboratory diagnostic tests targeted by the OIG will include the top 25 tests paid by the Medicare program in 2014, according to the 2016 HHS OIG Work Plan published November 2. "Previous OIG work has found that Medicare pays more than other insurers for certain high-volume and high-expenditure laboratory tests," the work plan states.

"Section 216 of the Protecting Access to Medicare Act of 2014 (PAMA) requires new Medicare payment rates for laboratory tests beginning in 2017 that are based on private payer rates and establishes processes for determining initial payments for new laboratory tests. Pursuant to a requirement of the [PAMA], OIG will conduct an annual analysis and monitor Medicare expenditures and the new payment system for laboratory tests."

In addition to clinical laboratory tests, the Work Plan lists the OIG's reviews and objectives for Medicare services provided by physicians, hospitals, and other providers.

The OIG is planning reviews involving accountable care organizations (ACOs), including an assessment of electronic health records used to support care coordination through ACOs, and ACO strategies and promising practices. The two ACO-themed reports are expected to be published in 2017.

Read the full 2016 HHS OIG Work Plan.

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