Medicare Seeks Your Feedback on MIPS Colonoscopy Episode

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    Caroll D. Koscheski, MD, FACG
    ACG Legislative and Public Policy Council Member, and ACG Board of Trustee

    As ACG and the GI societies notified you earlier this month, CMS recently announced that it will begin a trial run or test period for a “Screening/Surveillance Colonoscopy” episode of care.  We need your feedback and input!

    What does this mean? 

    From October 16 to November 20, 2017, ACG members may receive a confidential report with information about their performance on this draft episode of care.  According to CMS, the report is available for group practices and solo practitioners who meet a 10-episode case minimum during the measurement period of 06/01/16 to 05/31/17.

    The purpose of this report is to help improve the accuracy and understanding of the process, and for our members to provide feedback to CMS.

    Your Feedback is Important- Complete the Survey

    CMS will be seeking feedback from all stakeholders through an online survey.   Please complete this survey here.

    This survey opened on October 16, 2017 and closes at noon Eastern time on November 20, 2017.  The field test reports for group practices and solo practitioners will be distributed through the CMS Enterprise Portal, which CMS has previously utilized for “Quality and Resource Use” Reports.   If you do not already have an account, you can set one up and get access to a “Physician Quality and Value Programs” role in preparation for the field test report by using this guide.

    Some background- Why do we need to do this?

    MACRA requires CMS to develop an “episode of care” to include in the MIPS’ cost (Resource Use) performance category.  This performance category is designed to measure and compare the costs of your services versus other providers performing the same services.   Thankfully, CMS proposes that for both the 2017 and 2018 reporting years, this MIPS category will have no impact on your final MIPS score (weight of 0%).  However, this MIPS performance category will increase to 30% of your total MIPS score for the 2019 reporting year.  Thus, it is very important for these measures to be correct and with accurate attribution of costs.  ACG and the GI societies are part of the GI Technical Expert Panel, working with CMS on this very goal— to help get this correct.

    An “episode of care” is a defined group of health services, over a specific period of time.  The goal is to attribute medical costs to the corresponding medical provider.  How does CMS do this?  What do you do?  CMS looks at your reimbursement claims and other provider’s claims for the same patient and attempts to assign — or attribute — the cost of those patient’s services to a provider.  The theory being that one provider has primary control over the costs of those services for that patient.  This is where it gets tricky, because we all know that in reality, this may not be true.  Providers still submit Medicare fee for services claims as you would normally do.  This is all “behind the scenes” work at Medicare.

    CMS then looks at the claims and checks for a “trigger” service.  This will trigger a review of all services provided to a patient over that defined period of time.  CMS then includes and/or excludes certain services over that time-period, and produces a cost figure.  CMS then compares this cost to other providers falling into the same episode.  From there, CMS will assign a MIPS performance category to you.

    Hopefully this background provides a basic understanding of what happens, where the administrative work happens, who does the actual administrative work, how this gets complicated, and why it is very important for ACG members to be involved in this process.

    Caroll D. Koscheski, MD, FACG
    ACG Legislative and Public Policy Council Member
    ACG Board of Trustee

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