Weekly Roundup (August 7-August 11, 2023)
Physician payment, coding, coverage, and quality reporting news highlights.
Earlier this week, I participated in a sobering meeting on the nexus between climate change and the healthcare system. The healthcare sector is estimated to account for 8.5% of U.S. emissions, and climate change has been identified as the most significant public health challenge of the 21st century. Despite these gloomy statistics, I experienced a sense of hopefulness, learning how health systems, clinicians, and other stakeholders are working together to reduce the carbon footprint of healthcare. This is supported by recent efforts by the government, including President Biden’s Executive Order on Climate Crisis and the Inflation Reduction Act (IRA) of 2022, which made the single most significant investment in climate and energy in American history.
This summer, there has been what has seemed like a constant drumbeat of dire weather news with floods, heat waves, and fires. It has been hard to ignore. The latest being the devastating fires in Hawaii, where scientists say climate change is contributing to the current conditions. Thousands have had to evacuate and by Thursday night the death toll had climbed to 53, although it is expected to rise. For those who would like to help the Washington Post has identified reputable organizations accepting donations.
In the coming weeks, look for information, analysis, and resources on climate change and healthcare with a lens towards practicing clinicians and practices in this weekly email and on my website.
PAYMENT/ FUNDING
Biden Administration Announces $100 Million to Support Nursing Workforce. On August 10, 2023, the Biden Administration announced $100 million in awards to support the nursing workforce. These funds were awarded through the Health Resources and Services Administration as part of a larger effort to support the overall health workforce.
$8.7 million to help train licensed practical nurses and licensed vocational nurses to become registered nurses
$34.8 million to increase the number of primary care nurse practitioners, clinical nurse specialists, and certified nurse midwives trained and prepared to provide primary care services, mental health and substance use disorder care, and maternal health care
$30 million to support comprehensive residency and fellowship training programs to increase the number of trained advanced practice nurses in primary care
$26.5 million to provide low-interest loans and loan cancellation to incentivize careers as nursing school faculty
The intent of the funding is to incentivize applicants to a career in nursing, attract more nurses to teach, support registered nurses through more advanced training, and increase the number of primary care nurse practitioners.
PAYMENT INNOVATION/ QUALITY
2024 MIPS Payment Adjustments Released. On August 10, the Medicare agency released Merit-based Incentive Payment System (MIPS) Performance Feedback for the 2022 performance year, impacting 2024 Medicare fee-for-service payments. Clinicians and their staff can sign into the Quality Payment Program website to download their information.
The MIPS final score received by a MIPS-eligible clinician will determine if they receive a negative, neutral, or positive MIPS payment adjustment in 2024. Clinicians should note that CY 2022 is the last year for the MIPS exceptional performance adjustment, which has been helpful to many participants in increasing their final score and providing for a higher positive payment adjustment.
The 2024 MIPS payment adjustment ranges from -9% to +9% by statute. Due to the budget-neutral nature of the program and the fact that few participants are receiving negative adjustments, typically, the positive adjustments are well below the positive adjustment detailed in the statute. For example, the 2023 MIPS adjustment ranges from -9% to +2.33%, well below the +9% in law.
For 2024 the following adjustments have been announced based on a clinician’s 2022 Final MIPS Score:
0.00 – 18.75 points: Negative MIPS payment adjustment of -9%
18.76 – 74.99 points: Negative MIPS payment adjustment, between -9% and 0%, on a linear sliding scale
75.00 points: Neutral MIPS payment adjustment (0%) (referred to as the MIPS Performance Threshold)
75.01 – 88.99 points: Positive MIPS payment adjustment, greater than 0% (subject to a scaling factor to preserve budget neutrality)
89.00 – 100.00 points: Positive MIPS payment adjustment (subject to a scaling factor to preserve budget neutrality) AND eligible for additional adjustment for exceptional performance (subject to a scaling factor to account for available funds)
Since its implementation in 2017, the program has been criticized for being complex and burdensome. Stakeholders have urged Congress to address the problem of MIPS, and in its 2024 Medicare Physician Fee Schedule Proposed Rule, the Medicare agency requested feedback on the program from the public. While there is a desire to move on from MIPS, without Congressional action, there are limits to what the agency can do to revise the program.
CLIMATE CHANGE
HHS Launches National Dashboard on Heat-Related Illnesses. On August 9, 2023, the Department of Health and Human Services (HHS) launched a national dashboard to track health-related illnesses. The tool, Heat-Related Illness EMS Activation Surveillance Dashboard, will map emergency medical services responses to heat-related illnesses nationwide.
The Biden Administration has said they developed this tool to help communities address the growing climate crisis. Heat is considered the most dangerous of all extreme weather conditions. The National Weather Service estimates that in the last 30 days, 59,201,167 people in the U.S. have been under heat alerts. It was reported in the press that Phoenix recently ended a 31-day streak of temperatures over 110 degrees by dropping down to 108. This weather pattern impacts the health sector, including increased heat-related emergency department visits and hospitalizations.
Specifically, the dashboard will include national data on the number of heat-related EMS activations and heat-related deaths among patients alive when EMS officials arrive. It will also have some county and jurisdiction-level comparisons to national data points. The dashboard is anticipated to evolve as new data becomes available.
The Biden Administration has come under growing pressure from state and local leaders to do more to address the climate crisis. Traditional and go-to resources such as the Federal Emergency Management Agency are neither sufficient nor designed for these types of situations. The Administration created the Office of Climate Change and Health Equity (OCCHE) (although it has yet to be funded by Congress), and the President has set an ambitious goal of achieving a carbon pollution-free power sector by 20235 and a net zero emission economy by 2050. While we should expect to see more activities in this area by the Administration, the actual successful implementation of these efforts may be limited by the level of cooperation and support received from Congress and the limitations of the government alone to address these challenges.
In other climate-related news, OCCHE released its monthly Climate Health and Outlook Report for August 2023.
OPPORTUNITIES TO ENGAGE
Diagnostic Excellence Artificial Intelligence in Quality Measures Technical Expert Panel. The National Quality Forum (NQF) is convening an Artificial Intelligence (AI) in Quality Measures Technical Expert Panel (AI TEP) to help NQF develop a framework, principles, and possibly criteria that set standards for reviewing the use of AI methods in national quality measures. Nominations are due Wednesday, August 23, at 6 PM ET.
Public Listening Session on Telemedicine and Prescribing Controlled Substances. On September 12-13, 2023, the Drug Enforcement Administration (DEA) will host public listening sessions to receive comments from stakeholders on prescribing controlled substances via telemedicine. These listening sessions are in follow-up to a proposed rule issued in March 2023 on allowing the prescribing of certain controlled medications without an in-person visit. In May 2023, the DEA announced an extension of six months of COVID-19 telemedicine flexibilities for prescribing controlled pharmaceuticals while considering public comments before establishing a final policy.
Save the Date – November 15, 2023 - 2023 CMS Conference on Optimizing Healthcare Delivery to Improve Patient Lives. This virtual conference will convene leadership from the federal government, health provider organizations, and the patient advocacy community to focus on opportunities across the healthcare enterprise to reduce administrative burden, strengthen access to quality care, and make it easier for clinicians to provide that care. CMS will soon release additional information, including registration and agenda details.
OTHER UPDATES, IN BRIEF
U.S. Senator Cassidy Sends Letter to HHS on Surprise Billing. U.S. Senator Bill Cassidy, M.D. (R-LA), ranking member of the Senate Health, Education, Labor, and Pensions (HELP) Committee, sent a letter to the Department of Health of Human Services (HHS) raising concerns regarding the implementation of the No Surprises Act. The Senator, with several of his colleagues, previously sent a letter to the HHS on this topic back in December 2021.
The Senator asked HHS to respond to a series of questions by September 15, 2023. These questions relate to the Qualifying Payment Amount, Ensuring Timely and Accurate Payments, Independent Dispute Resolution (IDR) Process, Batching Challenges, the Administrative Fee, and Audits and Enforcement Authorities.
We reported last week that CMS temporarily suspended the IDR process. The agency shut down the IDR portal because of a decision by a federal district judge in Texas who agreed with plaintiffs that IDR fee increases and rules on claims batching violated the Administration Procedures Act.
Articles that Grabbed Our Attention. These articles grabbed our attention this week; we thought they would also interest you.
The average doctor in the U.S. makes $350,000 a year. Why? (Washington Post, August 4, 2023)
Medical coworking companies seek to attract independent physicians (Modern Healthcare, August 8, 2023)
Unstoppable: This doctor has been investigated at every level of government. How is he still practicing? (ProPublica, August 8, 2023)
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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