Electronic Health Records

Policy & Regulation News

How Health Data Infrastructure Factors into Fee Schedule Policies

By Frank Irving

- The American Medical Group Association (AMGA) has weighed in on proposed revisions to payment policies under the Medicare Physician Fee Schedule (MPFS) for calendar year 2016. The recommendations relate to several health data infrastructure issues that AMGA feels would need to be addressed to maximize the effectiveness of the MPFS.

Health data infrastructure factors in Medicare Physician Fee Schedule

AMGA President Donald Fisher, PhD, made the group’s positions known in a Sept. 8 letter to Andrew Slavitt, acting administrator of the Centers for Medicare and Medicaid Services.

AMGA, which represents 435 medical groups that employ nearly 170,000 physicians, commented in the following areas with health data infrastructure ramifications:

Telehealth services
CMS proposes adding several new codes to its Category 1 telehealth list for 2016 covering services similar to professional consultations, office visits and psychiatry services on the current list of telehealth services. “AMGA strongly supports expansion of Medicare coverage for telehealth services, and recognizes the need to not only expand covered services, but also consider the location of patients,” Fisher’s letter states, citing the example of frail elderly patients who find it difficult to attend frequent in-person visits.

Chronic Care Management (CCM) services
AMGA expresses concern about an additional beneficiary co-payment associated with the CCM code, which was finalized in 2015. The group says most of its member medical groups have long provided non-face-to-face care management services to patients with chronic conditions with no additional financial liability. CMS should consider establishing a process through which physicians could apply to waive to co-payment requirement for specific groups of patients who would benefit from CCM services, according to AMGA. Documentation could be handled by permitting patients to opt in to care management services verbally, with consent noted in the EHR system, the group says. AMGA also calls for CMS to eliminate the requirement for providers to give beneficiaries an electronic copy of their care plan because they already provide an after-visit summary that contains the plan of care.

CCM services for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)
AMGA supports CMS making additional payments for costs of CCM services that are not already captured in RHCs’ all-inclusive rate or the FQHC prospective payment system. However, the group points out that RHCs or FQHCs — which have never been eligible for meaningful use incentives — may not have the health information technology in place to support requirements of coding for CCM services. “[For] those RHCs and FQHCs that have the necessary information technology infrastructure, we feel implementation of the CCM code is a step in the right direction, given the critical role these facilities play in improving access to primary care services in areas of the country that otherwise may not be able to furnish these services to patients,” the letter states.

Merit-Based Incentive Payment System (MIPS)
MIPS, passed in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), will sunset the Physician Quality Reporting System, the Medicare EHR Incentive Program and the Value-Based Modifier. AMGA supports the proposed rule’s enumerated subcategories of clinical practice improvement activities to include expanded practice access, population management, care coordination, beneficiary engagement, patient safety and practice assessment, and participation in alternative payment models. AMGA suggests that participation in programs such as Measure Up/ Pressure Down, which aims to achieve high blood pressure control in 80 percent of medical groups’ patients with the condition, should qualify as a clinical practice improvement activity in the MIPS.

Alternative Payment Models (APMs)
CMS will be issuing a Request for Information (RFI) on certain MACRA provisions related to implementation of APMs. Topics will include increasing transparency of physician-focused payment models, criteria for submission and review of such payment models, incentive payments for participation in eligible APMs, and integrating Medicare APMs in the Medicare Advantage program, among others. AMGA intends to respond to the RFI when it is issued. The group notes that several issues have surfaced in implementation of the Medicare Shared Savings Program and Pioneer ACO Program; those challenges could provide insight into the challenges that all APMs will need to overcome to ensure success, according to AMGA. They include “developing effective attribution methodologies so that healthcare providers will have a clear sense of the patients they are responsible for under the models, patient engagement opportunities, timely data-sharing between healthcare providers and CMS, and greater transparency around financial benchmarking for the programs,” the letter concludes.