Sheila Madhani Sheila Madhani

Weekly Roundup (October 9-13, 2023)

Physician payment, coding, coverage, and quality reporting news highlights.

Lots of chatter and LinkedIn updates this week from HLTH 2023, held in Las Vegas. I know that at HLTH 2023, you can hobnob with the likes of former first daughter and current philanthropist Chelsea Clinton and international superstar (as described in his bio) Nick Jonas – but let’s not forget the other big healthcare conference this week – the 2023 Annual Conference of the American Health Information Management Association (AHIMA) in Baltimore (full disclosure, I’m a member!). AHIMA 2023 was the place to be if you are a true coding guru or health data nerd. Wherever you were this week, in Las Vegas, Baltimore, or elsewhere, I hope it was productive, satisfying, and successful. Now, on to the update!

PAYMENT

GOP Doctors Caucus Releases Physician Fee Schedule (PFS) Proposal. Politico and Bloomberg Law reported that the GOP Doctors Caucus released a policy proposal to revise the payment methodology to update the Medicare PFS more comprehensively than physician payment fixes implemented in recent years. Aspects of this proposal are similar to policies advocated by the American Medical Association and other medical specialty societies.

The proposal aims to:

  • Increase funding for the physician fee schedule by increasing the budget neutrality threshold, which triggers budget neutrality adjustments. The current budget neutrality threshold of $20,000 was established in 1992 and has never been updated.

  • Confirm the appropriateness of budget neutrality adjustments by providing a pathway to review and correct for over and under-utilization estimates that may have triggered a budget neutrality adjustment in previous years.

  • Bring greater stability to the fee schedule and mitigate fluctuations in relative value units by coordinating the timing of data updates to direct practice expense cost inputs (i.e., clinical staff wages, supplies, and medical equipment).

  • Limit the year-to-year variance on the Medicare Physician Conversion Factor to no more than 2.5%.

This proposal joins the Inflationary Update to Medicare Physician Payments (HR 2474) and will be closely reviewed by stakeholders. For those interested in Congress addressing what at this point is generally universally considered as fundamental flaws with the Medicare physician payment system, the introduction of this proposal will be viewed as a positive development. Yet, with the current disarray in Congress and the (appropriately) focused attention on recent international events, the future of this or any other proposal that tries to implement comprehensive and complex changes to the fee schedule seems unclear.

QUALITY

Performance Year 2022 Merit-based Incentive Payment System (MIPS) Data Validation and Audits (DVAs) Will Launch in November. CMS conducts DVAs on randomly selected MIPS participants as authorized by statute to test the accuracy and completion of MIPS data. CMS recently announced that between November 2023 and March 2024, selected participants will receive a request for documents from CMS contractor Guidehouse. Clinicians will have 45 days to respond. Requested documents may include copies of claims, medical records for applicable patients, or other resources used in the data calculations for MIPS measures, objectives, and activities. Primary source documentation may also include verifying records for Medicare and non-Medicare patients where applicable.

CODING

Key Dates for the February 2024 CPT Editorial Panel Meeting Announced. It was announced this week that registration for the 2024 CPT Editorial Panel meeting will open on November 6. The public agenda will be posted on December 1. This meeting will be held in San Diego, California, and is the first of three CPT meetings of the 2026 CPT/ Medicare PFS cycle.

OTHER NEWS, IN BRIEF

Telehealth

  • Prescribing Telehealth Flexibilities Extended Through the End of 2024. Last Friday, the Drug Enforcement Agency (DEA) announced an extension of telehealth flexibilities through the end of 2024 to prevent lapses in care as the agency develops a more permanent policy. This is the second extension. Initially, flexibilities were extended through November 11. Stakeholders advocated for maintaining telehealth flexibilities by commenting on a proposed rule and participating in a recent two-day listening session. The flexibilities, implemented during the COVID-19 pandemic, allowed for prescribing controlled substances remotely, waiving the requirement of an in-person visit.

  • Medical Community Urges CMS Not to Require Telehealth Clinicians to Report Home Addresses on Enrollment and Claim Forms. During the COVID-19 pandemic, clinicians who provided telehealth services from their homes were not required to report their home address. In July, the agency announced that beginning January 1, 2024, reporting home addresses will be required if the clinician renders service from their home. The medical community has raised concerns that this poses privacy and safety concerns.  On October 4, the American Hospital Association submitted a letter to CMS requesting them to remove this requirement permanently. Additionally, the telehealth coalition, the Alliance for Connected Care, is soliciting organizational support for a similar letter. Responses are requested by COB on Tuesday, October 17.

Digital Health

  • Food and Drug Administration (FDA) Seeks Nominations for Digital Health Panel. The FDA announced the creation of a new Digital Health Advisory Committee, which will launch in 2024 to help the agency understand scientific and technical issues related to digital health technologies (DHTs). The committee will contribute to the agency’s understanding of the benefits, risks, and clinical outcomes associated with using DHTs. The agency seeks nominations from technically qualified experts (e.g., clinical medicine, engineering, biological and physical sciences, biostatistics, and food sciences) with experience interpreting complex data. Candidates must be able to analyze detailed scientific data and understand its public health significance.

    In other digital health news, AdvaMed announced the creation of a digital health division to promote the role of data and digital medical technologies in healthcare. The division will focus on four core policy areas: regulation, payment and healthcare delivery, data stewardship, and privacy and cybersecurity.

ARTICLES THAT GRABBED OUR ATTENTION

This week, these articles grabbed our attention; we thought they would also interest you.

UPCOMING EVENTS

Events scheduled for next week (October 16-20, 2023) are below. For a complete list of upcoming health policy events and deadlines, please visit our new Health Policy Calendar.

Oct. 15

  • House Budget Committee Health Care Task Force, Request for Information (RFI) to Improve Patient Outcomes and Reduce Health Spending Comment Deadline. The task force seeks solutions to reduce healthcare spending, examine opportunities to modernize and personalize the healthcare system, and support policies to fuel innovation and increase patient access to quality and affordable care.

Oct. 17

Oct. 18

  • Enabling Patient Access to Health Data for Actionable Results Event. The event is sponsored by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) for an event focused on patient access to their health data.

 

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For more information and questions, please contact:

Sheila Madhani, MA, MPH

Madhani Healthcare Consulting, LLC

Email: smadhani@madhani-health.com

www.madhani-health.com

Tel: (202) 679-2977

 

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