American Society of Regional Anesthesia and Pain Medicine August 2016 - 4


quality payment program streamlines several quality reporting
programs in the new MIPS. The first performance period for
MIPS will be from January 1, 2017, through December 31,
2017. MIPS combines the requirements of the Physician Quality
Reporting System, the Value Modifier Program, and the Medicare
Electronic Health Record Incentive Program into a single, improved
reporting and quality-based payment program. Therefore, the last
performance period for these separate reporting programs will be
January 1, 2016, through December 31, 2016. The first payment
year for MIPS will be 2019, based on the first performance period
of 2017.
A single MIPS composite performance score will measure performance
in four weighted categories on a 0-100 point scale: quality, advancing
care information (previously "Meaningful Use" of certified EHR),
clinical practice improvement activities, and cost (called "Resource
Use"). The weights for the MIPS performance categories on the first
year will be 50%, 25%, 15%, and 10%, respectively. You may want
to review the 962-page document, which can be found at http://
federalregister.gov/a/2016-10032. There are three important sections
within this document that require your attention: the clinical condition
and treatment episode-based resource use measures in Table 4 on
page 148, Table 5 on page 154, and the proposed clinical practice
improvement activities inventory measures in Table H on page 946.
These measures will affect a clinician's MIPS total performance score.
As noted, the quality category accounts for 50% of the MIPS score in
the first year. For this category, clinicians would choose six measures
to report (versus the nine measures currently required under Physician
Quality Reporting System). In addition, for individual clinicians
and small groups (2-9 clinicians), MIPS calculates two population
measures from claims data, meaning there are no additional reporting
requirements for clinicians for population measures. For groups with
10 clinicians or more, MIPS calculates three population measures. The
measures are each worth up to 10 points for a total of 80-90 possible
points depending on group size. For a quick review on the program,
follow the link in our website where you can find a link to a slide deck
created by CMS.
I have formed a task force, which eventually will become the
Performance Outcomes and Process Improvement Committee,
to work with a consultant to respond to CMS on our members'
behalf, to make comments on the applicability and feasibility of
complying with the performance measures on the four weighted
categories. The task force is cochaired by Dr David Provenzano
and Dr Alexandru Visan. Dr Carlos Pino and Dr Kevin Vorenkamp
will provide input for the Chronic Pain Group, and Dr Arthur
Atchabahian, Dr Sanjay Sinja, and Dr Doug Jaffe will do so for the
Regional Anesthesia/Acute Pain Group. Dr Asokumar Buvanendran

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and I are the two executive board members on the task force. This
is a critical juncture for our subspecialties because the law requires
MIPS to be budget neutral on an aggregate basis (in other words,
across all Medicare payments to clinicians). Therefore, clinicians'
MIPS scores would be used to compute a positive, negative, or
neutral adjustment to their Medicare Part B payments. In the first
year, depending on the variation of MIPS scores, adjustments are
calculated so that negative adjustments (loss in your professional
fee income) can be no more than 4% and positive adjustments
are generally up to 4%. The positive adjustments will be scaled up
or down to achieve budget neutrality, meaning that the maximum
positive adjustment could be lower or higher than 4%. Per the law,
both positive and negative adjustments would increase over time.
Additionally, in the first 5 payment years of the program, the law
allows for $500 million in an additional performance bonus that
is exempt from budget neutrality for exceptional performance.
This exceptional performance bonus will provide high performers
a gradually increasing adjustment based on their MIPS score
that can be no higher than an additional 10%. As specified under
the statute, negative adjustments would increase over time, and
positive adjustments would correspond. The maximum negative
adjustments for each year are 4% for 2019, 5% for 2020, 7%
for 2021, and 9% for 2022 and after. The ASRA Board and our
administrative office are committed to participate in the ongoing
discussions with CMS on this topic, and we will work with the
American Society of Anesthesiologists and other pain societies to
present a unified front to CMS. We will keep you informed on new
developments.
Our Executive Director, Angie Stengel, MS, CAE, has created a flow
chart that will help you understand the proposed reimbursement
changes under MIPS.
THE UGLY
The abovementioned changes in CMS will also apply to general
practitioners, NPs, and PAs, who will need to show value when
providing pain management for their patients. Since a US Food
and Drug Administration advisory panel concluded that physician
training on the risks of prescription opioids should be mandatory,
I am concerned that if this recommendation is approved, a new
variable to the "Perfect Storm" scenario that I described in my last
President's Message will be added to the already disconcerting
equation. If passed, this may potentially give general practitioners
an excuse not to provide pain management support and, with
that, prescribe opioids for their Medicare/Medicaid patients. The
results will be devastating for the significant number of patients
with chronic pain in the United States. We will be following these
developments and will keep you informed.

American Society of Regional Anesthesia and Pain Medicine
2016
http://www.federalregister.gov/a/2016-10032 http://www.federalregister.gov/a/2016-10032 https://www.asra.com/news/105/asra-provides-formal-comments-on-mips-an https://www.asra.com/news/105/asra-provides-formal-comments-on-mips-an https://www.asra.com/news/105/asra-provides-formal-comments-on-mips-an https://www.asra.com/news/105/asra-provides-formal-comments-on-mips-an
Table of Contents for the Digital Edition of American Society of Regional Anesthesia and Pain Medicine August 2016
