Previous Advocacy Updates

Time is running out to report your 2017 data if you are included in the Centers for Medicaid and Medicare Services, (CMS) Quality Payment Program (QPP) Merit-based Incentive Payment System (MIPS). As a reminder, your 2017 data will determine how your 2019 Medicare payments will be adjusted up, down, or not at all. The deadline to enroll in the CAP’s MIPS Reporting Solution is January 5, 2018.

The American Medical Association (AMA) continues to work with physician organizations like the CAP to tackle issues from regulatory burden relief to payment for services provided to patients. At the recent AMA 2017 Interim Meeting, physicians outlined health reform issues and regulatory relief concerns. A delegation of pathologists, led by the CAP, advocated on behalf of laboratory medicine.

The Centers for Medicare & Medicaid Services (CMS) published the final Medicare 2018 clinical laboratory fee schedule (CLFS) despite the CAP and other industry groups’ reservations about the laboratory data collection process and methodology to calculate the new rates. The CAP has called this collection process flawed and continues to urge the CMS to delay the implementation of the new fee schedule to allow for time to fix their flawed data collection process.

To increase transparency and accountability in Medicare’s local coverage process, Congress re-introduced the Local Coverage Determination Clarification Act of 2017 in the Senate and House. The LCD bill continues to gain momentum and make strides in both the House and Senate with the total of 24 members of the House and 14 senators to sponsor the bill.

Many pathologists may not know that 15% of your Merit-based Incentive Payment System (MIPS) bonus is based on affirming that you do certain quality improvement activities in your practice. The CAP has identified several Improvement Activities options to help members get the most of their 2017 MIPS reporting tool.

The CAP’s efforts to protect the value of pathology services were adopted by the Centers for Medicare and Medicaid Services (CMS) in final Medicare regulations affecting reimbursements next year.

The CAP was one of the provider groups at the Centers for Medicare and Medicaid Services (CMS) Patients Over Paperwork Initiative, a cross-cutting, collaborative process that evaluates and streamlines regulations with a goal to reduce unnecessary burden, increase efficiencies, and improve the beneficiary experience.

With serious concerns regarding the data collection and methodology used to calculate new rates for clinical laboratory tests, the CAP strongly urged the Medicare program to delay its implementation of the proposed 2018 Medicare clinical laboratory fee schedule (CLFS).

The CAP continues to engage and advocates with other leading laboratory stakeholders regarding new clinical laboratory payment rates. On October 6, the CAP along with the American Clinical Laboratory Association, the National Independent Laboratory Association, Point of Care Testing Association, and AvaMedDX, sent a joint letter to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma to suspend implementation until the agency can address the significant deficiencies in its process to establish new clinical laboratory payment rates.

The CAP is pleased to announce it's offering a 2017 MIPS Reporting Solution as a free benefit for CAP members. The 2017 MIPS Reporting Solution was announced during CAP17, when the CAP launched its new Pathologists Quality Registry for pathologists. Learn more about the 2017 MIPS Reporting Solution and enroll today.

On September 30, the Senate failed to have enough votes to repeal portions of the Affordable Care Act (ACA), but the Senate fiscal year 2018 budget resolution suggests the chamber could still use it to repeal key parts of the current law in 2018. The budget resolution includes a reserve fund, just in case the committees decide they want to tackle some elements of repeal.

On September 13, Sens. Lindsey Graham (R-SC), Bill Cassidy (R-LA), Dean Heller (R-NV), and Ron Johnson (R-WI) released an updated legislative proposal to repeal and replace portions of the Affordable Care Act (ACA). The new bill would roll federal funding for the ACA’s premium subsidies and Medicaid expansion into a single pool, and then convert it into block grants to the states. The legislation would also convert federal Medicaid funding to a per capita allotment and limit growth of federal Medicaid spending starting in 2020.

The Medicare program published the 2018 clinical laboratory fee schedule utilizing a new methodology based on private payer rates for tests collected from a small segment of providers. The CAP has called this collection process flawed and continued to urge the Centers for Medicare & Medicaid Services to delay of the implementation of the new fee schedule.

CAP Advocacy consistently works with Medicare officials to help ease the negative effects of the evolving Quality Payment Program (QPP) reporting requirements for pathologists and laboratories. Through a strategy developed by the Council on Government and Professional Affairs and Economic Affairs Committee, the CAP advocates to ensure pathologists can participate in the Quality Payment Program by providing resources to its members as the Centers for Medicare & Medicaid Services begins implementation of payment reforms in 2017.

The CAP advocated for the Centers for Medicare & Medicaid Services (CMS) to accept all the physician work recommendations for pathology services used to calculate professional component and global payment rates in the proposed 2018 Medicare Physician Fee Schedule, which was released in July.

The CAP advocated for reducing regulatory burdens on pathologists participating in the Medicare Merit-based Incentive Payment System (MIPS) and ensuring pathologists are fairly compensated in MIPS.

The CAP and other members of the Coalition of Hospital-Based Physicians are urging the Maryland Insurance Department to amend a proposed network adequacy rule to ensure it includes critical hospital-based physician specialties.

The CAP's state advocacy efforts help to secure the Centers for Medicare and Medicaid Services (CMS) requirement for insurers who participate in federally-facilitated health insurance exchanges to document their process for monitoring access to hospital-based physicians, including pathologists, at in-network hospitals.

The Centers for Medicare and Medicaid Services (CMS) announced that some clinicians may be exempt from participating in the Quality Payment Program through a Special Status calculation, including non-patient facing and hospital-based clinicians. The CAP had strongly advocated for this exemption to ensure flexibility for pathologists to participate in the program.

Registration is now open for key CAP policy and advocacy courses and roundtable discussions important to the pathology specialty during CAP17 at the Gaylord National Harbor from October 8–11, 2017.