Thankful Wishes: Message from ACRO President Dr. Joanne Dragun

As we enter the holiday season, let us all take a moment to consider the many reasons for a grateful heart. We have weathered unprecedented challenges in healthcare and our practices yet we work bravely shoulder to shoulder with our colleagues focusing on the very best therapy and compassionate care for our patients. The American College of Radiation Oncology, devoted to you and your specialty, stands with you. Our members have been tireless in bringing forth new programs, participating on our committees, and networking across the country and through private and academic practices to ensure that ACRO reflects your needs and interests and fiercely advocates for the specialty.

Soon we will celebrate together. We anticipate seeing all of you in person in March where we will enjoy a fantastic program while engaging with each other in beautiful sunny Ft. Lauderdale.

I want to personally thank each of you for your continued support of the College. There is great momentum gathering as we come out of the pandemic and into a renewed and energized future for ACRO. On behalf of the Board of Chancellors and our new and gifted Executive Director, we are grateful for your continued commitment and offer our sincerest wishes for a very Happy Thanksgiving for you and your families.

-Joanne Dragun, MD, FACRO
ACRO President

CMS to Apply MIPS Automatic Extreme & Uncontrollable Circumstances Policy for 2021 Performance Year

The following message is from the Centers for Medicare & Medicaid Services:

The Centers for Medicare & Medicaid Services (CMS) continues to provide relief where possible to clinicians responding to the 2019 Coronavirus (COVID-19) public health emergency (PHE). We’re applying the Merit-based Incentive Payment System (MIPS) automatic extreme and uncontrollable circumstances (EUC) policy to ALL individually eligible MIPS eligible clinicians for the 2021 performance year (PY). Please note that this announcement is for PY2021 only.

The automatic EUC policy only applies to MIPS eligible clinicians who are eligible to participate in MIPS as individuals. The automatic EUC policy doesn’t apply to groups, virtual groups, or Alternative Payment Model (APM) Entities.

MIPS eligible clinicians who are eligible to participate in MIPS as individuals

You don’t need to take any action to have the automatic EUC policy applied to you. You’ll be automatically identified and will have all 4 MIPS performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless you 1) submit data in 2 or more performance categories, or 2) have a higher final score from group or APM Entity participation.

Small practices reporting Medicare Part B claims measures

Under current policies, we automatically calculate a quality score from Medicare Part B claims measures at the individual and group level.

  • Clinicians in small practices that report Medicare Part B claims measures who are only eligible to participate in MIPS as part of a group aren’t covered by the automatic EUC policy and will receive the group’s final score. (To identify these clinicians, sign in to qpp.cms.gov, navigate to the “Eligibility & Reporting” page and click “View Clinician Eligibility”. Clinicians who are only eligible to participate as part of a group will have a green check mark next to “Group”; there won’t be a green check mark next to “Individual”.)
  • Some small practices may not be aware of the implications of their PY 2021 claims reporting due to some of the policies we introduced at the onset of the COVID-19 PHE.
  • As a result, these small practices may wish to request performance category reweighting on behalf of the group through the PY2021 EUC Exception Application, citing COVID-19 as the triggering event.
  • PY2021 EUC Exception Applications can be submitted by signing in to qpp.cms.gov and clicking Exception Applications on the left-hand navigation.

Groups

The automatic EUC policy doesn’t apply to groups. You don’t need to take any further action if you’re not able to submit data for the 2021 performance year. Group participation is optional (specific guidance for small practices noted above), and your individually eligible MIPS eligible clinicians qualify for the automatic EUC policy if you don’t report at the group-level on their behalf. (If you submit data at the group level on behalf of your MIPS eligible clinicians, the group will receive a MIPS final score based on the data submitted.) Your MIPS eligible clinicians will have all 4 performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless 1) they submit data in 2 or more performance categories, or 2) they have a higher final score from group or APM Entity participation.

Virtual Groups

MIPS eligible clinicians in a virtual group will receive a payment adjustment based on the virtual group’s final score, even if no data is submitted. (When no data is submitted for the virtual group, the MIPS eligible clinicians in the virtual group could receive the maximum negative payment adjustment of -9% in the 2023 payment year.)

  • If you’re unable to submit data for the 2021 performance year as a result of the ongoing COVID-19 PHE, you can submit a PY2021 EUC Exception Application on behalf of the virtual group, citing COVID-19, to request reweighting for all 4 performance categories.
  • PY2021 EUC Exception Applications can be submitted by signing in to qpp.cms.gov and clicking Exception Applications on the left-hand navigation through December 31, 2021.

APM Entities

The automatic EUC policy doesn’t apply to APM Entities. You don’t need to take any action if you’re not able to submit data for the 2021 performance year. APM Entity participation is optional (specific guidance for small practices noted above), and your individually eligible MIPS eligible clinicians will have the automatic EUC policy applied to them if you don’t report at the APM-Entity level on their behalf. (If you submit data at the APM-Entity level on behalf of your MIPS eligible clinicians, the APM Entity will receive a MIPS final score based on data submitted.) Your MIPS eligible clinicians will have all 4 performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless 1) they submit data in 2 or more performance categories, or 2) they have a higher final score from group or APM Entity participation.

If your APM Entity would like to request performance category reweighting for the 2021 performance year, you must submit an EUC application.

  • PY2021 EUC Exception Applications can be submitted by signing in to qpp.cms.gov and clicking Exception Applications on the left-hand navigation through December 31, 2021.

Medicare Shared Savings Program ACOs

The MIPS Automatic EUC policy doesn’t apply to Shared Savings Program Accountable Care Organizations (ACOs). ACOs can submit a PY2021 EUC Exception Application on behalf of its MIPS eligible clinicians if they are unable to report via the Alternative Payment Model (APM) Performance Pathway (APP). To submit a PY2021 EUC Exception Application, ACOs must demonstrate that greater than 75% of its MIPS eligible clinicians would be eligible for reweighting the Promoting Interoperability performance category. ACOs can submit PY2021 EUC Exception Applications by signing in to qpp.cms.gov and clicking Exception Applications on the left-hand navigation through December 31, 2021.

Note: The Shared Savings Program Quality EUC policy for determining shared savings and losses applies to all Shared Savings Program ACOs for performance year 2021. CMS considers all ACOs to be affected by the COVID-19 PHE and the Shared Savings Program EUC policy applies for PY2021. ACOs that are able to report quality data via the APP and meet MIPS data completeness and case minimum requirements will receive the higher of their ACO quality score or the 30th percentile MIPS quality performance category score. ACOs that are unable to report quality data via the APP and meet the MIPS quality data completeness and case minimum requirements, will have their quality score set equal to the 30th percentile MIPS quality performance category score.

Additional Resources

For more information, please see the Quality Payment Program COVID-19 Response webpage on the QPP website. You can contact the Quality Payment program at 1-866-288-8292 (TRS: 711), Monday through Friday, 8AM-8PM ET or by e-mail at: QPP@cms.hhs.gov.

Disclaimer: The contents of this listserv do not have the force and effect of law and are not meant to bind the public in any way, unless specifically incorporated into a contract. This listserv is intended only to provide clarity to the public regarding existing policies under the law.

COVID-19 Health Care Staff Vaccination IFC-6: Presentation Slides & Video

On November 7, CMS hosted a stakeholder call regarding the COVID-19 Omnibus Vaccine Rule (IFC-6).

CMS has posted the presentation slides and a recording of the stakeholder call for your convenience.

To view the slides, click here. To view the video, click here.

In addition to the resources above, CMS has prepared a frequently asked questions document, available here.

The next stakeholder call will be held on Wednesday, November 10 from 3:30 – 4:30 PM EST. To register in advance, click here.

After registering, you will receive a confirmation email containing information about joining the webinar. Please note: they can only accommodate 10,000 participants so register early to guarantee your participation.

COVID-19 provider relief fund phase 4 and rural payments

The following is an update from the American Medical Association:

The Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), has announced a new application cycle for $25.5 billion in COVID-19 provider funding (Phase 4). The application for the funds is open now, and will close on October 26, 2021 at 11:59 p.m. ET. Applicants will be able to apply for both Provider Relief Fund (PRF) Phase 4 and American Rescue Plan (ARP) Rural payments during the application process. In order to streamline the application process and minimize administrative burdens, providers will apply for both programs in a single application.

PRF Phase 4 is open to a broad range of providers with changes in operating revenues and expenses. ARP Rural is specifically available to providers who serve rural patients covered by Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP). See a detailed list of eligible provider types here.

HHS recently hosted a briefing session to provide information about these upcoming funding opportunities – view the video here. HRSA will also host webinar sessions featuring guidance on how to navigate the application portal.

Real time technical assistance is available by calling the Provider Support Line at (866) 569-3522, for TTY dial 711. Hours of operation are 8 a.m. to 10 p.m. CT, Monday through Friday.

Driving Quality in the US: How CMS Evaluates its Measure Portfolio

The following is a message from the Centers for Medicare & Medicaid Services (CMS):

The Centers for Medicare & Medicaid Services (CMS) is pleased to invite the public to attend its upcoming webinar titled Driving Quality in the US: How CMS Evaluates its Measure PortfolioQuality measures are an important tool that CMS uses to assure quality healthcare for beneficiaries—but how does CMS make certain that the measures in its portfolio are effective? This webinar will walk audiences through CMS tools and processes, specifically the MMS Blueprint, Pre-rulemaking process, Quality Measure Index, and Impact Assessment, to evaluate the quality of its quality measures throughout the measure lifecycle. The webinar will also provide information about key quality measurement resources available to the public. The webinar will be offered twice in July:

      • Tuesday, July 13, 2021, from 1:00 p.m. – 2:00 p.m., ET (Register here)
      • Wednesday, July 14, 2021, from 3:00 p.m. – 4:00 p.m., ET (Register here)

Please register in advance if you can attend, as space will be limited. We request that you please only register for an event if you plan to attend. We hope you can join us and look forward to your questions! For questions about the webinar, please contact MMSSupport@battelle.org.

ACRO Leadership Meets with EviCore to Address Concerns

Senior leaders of ACRO’s Government Relations & Economics Committee (GREC) had a recent meeting with EviCore to express concern about their coverage criteria for Breast and Prostate Hypofractionation and the process they undertake when considering policy implementation.   The meeting was in response to a communication drafted by ACRO leadership highlighting the patient safety concerns we have with their coverage criteria. A copy of that letter can be found here.

EviCore has committed to reviewing our concerns with this current coverage policy and has agreed to further discussions on the best way to involve the College before EviCore policies are implemented, such as the opportunity to comment on draft EviCore policies prior to their adoption.   The meeting was a positive first step in opening communications between our organizations which could have a profound impact on one of the major administrative burdens for our members and your patients.

According to a recent survey conducted by the American Medical Association, an overwhelming majority (83%) of physicians report that the number of prior authorizations required for medical services has increased over the last five years. This remains an area that as your representative, ACRO is committed and will continue to actively advocate on behalf of its members.

OSHA Announces COVID-19 Safety Rule for Health Care Industry

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has announced it will issue an emergency temporary standard to protect healthcare workers from contracting coronavirus. The standard focuses on healthcare workers most likely to have contact with someone infected with the virus. OSHA announced the new standard alongside new general industry guidance, both of which are aligned with Centers for Disease Control and Prevention guidance.

Learn more:

News articles:

CMS Announcement on MIPS Cost Category

The following is a message from the American Medical Association:

Today, the Centers for Medicare & Medicaid Services (CMS) announced that the 2020 MIPS Cost Performance Category will be reweighted to 0% of the final score even if eligible physicians or groups submitted 2020 data in other MIPS categories in light of the impact of the COVID-19 pandemic. For over a year, the AMA has been recommending that CMS zero out this category during the pandemic for several reasons, including concerns that decreases in patient visits and increases in the costs of caring for patients with COVID-19 could unfairly penalize physicians. We applaud CMS for holding physicians harmless from unfair evaluations in the MIPS Cost Performance Category as a result of the COVID-19 pandemic.

The AMA also strongly supports CMS’ decision to release the 2018 and 2019 cost measure benchmark files, which we will review closely to identify the target spending for those years, how the benchmarks capture any variations in spending, and whether the benchmarks are leading to fair and valid comparisons among physicians. Again, the AMA has been recommending to CMS for a while that the agency should publish the data.  In April, the AMA and 47 national medical specialty societies sent a letter urging CMS to immediately release the MIPS cost benchmarks to increase transparency in how the agency evaluates physician performance in the Cost Performance Category in MIPS and to allow physicians and other stakeholders to assess the measures for validity and opportunities to reduce spending. We anticipate this information will be informative for specialty societies that are engaged in the ongoing development of new episode-based cost measures and MIPS Value Pathways (MVPs).

AMA-sponsored study on physician experiences with MIPS

The following is a message from the American Medical Association:

The results of a study conducted by Weill Cornell Medicine that was sponsored by the AMA and the Physicians Foundation have now been published. Researchers conducted 30 in-depth, semi-structured interviews with physician leaders in small and medium internal medicine and general surgery practices and large multispecialty practices about their experiences participating in Medicare’s Merit-based Incentive Payment System (MIPS). An article published in the Journal of General Internal Medicine provides qualitative results of physicians’ experience with the program, while an article published in JAMA provides quantitative insights into the cost of participating in MIPS and MIPS APMs.

Among the interesting qualitative findings:

  • MIPS is viewed as a continuation of previous programs and a precursor of future programs;
  • Performance measures are more relevant to primary care practices than other specialties
  • Leaders are conflicted on whether the program improves patient care
  • Participation creates administrative burden, exacerbated by frequent programmatic changes
  • Incentives are small relative to the effort
  • External support for participation can be helpful

In terms of cost, researchers found:

  • Annual cost of participation is about $12,000 per physician
  • Annual time spent by clinicians and staff is about 200 hours per physician
  • Costs per physician were predictably higher for smaller practices and for APM participants

Radiation Oncology Policy Update, May 2021

ACRO Members: The May issue of the Radiation Oncology Policy Update is now available. Some of the topics in this issue include:

  • ACRO joins coalition of stakeholders urging lawmakers to support provider stability
  • President Biden releases FY 2022 budget proposals
  • President Biden signs sequester suspension bill into law
  • Broad coalition challenges CMS Medicare prior authorization growth
  • CMS issues new guidance enforcing price transparency rule
  • Study finds telehealth increases downstream care

Just log in to your member account from the Advocacy tab to view the full update.