DHPA

  • Home
  • About Us
    • Leadership
      • Executive Committee
      • Board Members
    • DHPA Members
    • Contact Us
    • Join Us
  • Advocacy
    • Patient Access to Independent GI Care
      • Colorectal Cancer Screening
    • Diversity Equity and Inclusion
    • Modernizing the Stark Law
    • Saving the IOASE
    • Pathology Services Utilization
  • Resources
    • Independent GI Careers
    • Research
    • Fact Sheets
    • Letters to Policymakers
    • Leadership Webinar Series
  • Newsroom
    • Press Releases
    • DHPA in the News
    • GI News Round Up
  • Take Action

August 21, 2017

DHPA Comments on CY 2018 Updates to Quality Payment Program

DHPA has filed comments in response to CMS’s CY 2018 Updates to the Quality Payment Program (“QPP”) Proposed Rule. In its comment letter, DHPA provided three specific suggestions for CMS to consider incorporating into the Final Rule to ensure Medicare beneficiaries’ continued access to critically important drug treatments and to facilitate greater participation by independent gastroenterology practices in payment systems mandated by MACRA.

First, DHPA urged CMS to protect patient access to Medicare Part B drugs administered in the physician office by not applying MIPS payment adjustments to the actual cost of Part B drugs. At a minimum, DHPA requested that CMS delay doing so until this purported “clarification” in the application of MIPS payment adjustments can be reevaluated as part of the notice-and comment rulemaking process for the CY 2019 QPP. Under the Proposed Rule, physicians would risk administering Part B drugs at a loss, especially when larger negative payment adjustments are applied in later years. DHPA argued that this would pose a direct threat to patient care and should not be implemented without CMS issuing a formal proposal and soliciting comment from stakeholders.

Second, DHPA requested that CMS expand the authority of the Physician-Focused Payment Model Technical Advisory Committee (PTAC) to approve Physician-Focused Payment Models (PFPMs) as a means of reducing the substantial backlog of Alternative Payment Model (APM) proposals in front of PTAC and CMS. DHPA also requested that CMS take the following steps to bolster the process for development and implementation of PFPMs:

  • Commit to a 90-day period for PTAC to review and decide whether to approve a proposed PFPM as an Advanced APM or MIPS APM, and to approve a certain number of PTAC-proposed PFPMs as Advanced APMs each year;
  • Provide clinicians with clearer guidance in their development of PFPM proposals by publishing relevant, objective benchmarks that will be used by PTAC and CMMI to approve submitted models; and
  • Apply a rebuttable presumption that, at a minimum, CMS will adopt any PFPMs approved by PTAC as MIPS APMs.

Lastly, DHPA commended CMS for its proposals to create greater flexibility for MIPS reporting at the virtual-group level and requested that CMS finalize the proposals with respect to “virtual groups” as a mechanism of encouraging specialty practices to participate in MIPS. DHPA also urged CMS to seek additional statutory authority from Congress to permit MIPS reporting at the virtual-group level not merely for group practices with 10 or fewer physicians (as MACRA currently allows), but for all groups practices regardless of size.

DHPA looks forward to working with CMS to continue the transition to the delivery and payment systems created by MACRA in a way that promotes and protects the high quality, cost-efficient care that gastroenterologists and other physician specialists furnish to Medicare beneficiaries in the independent practice setting.

Click here to read the full comment letter.

Filed Under: Advocacy, Letters to Policymakers, Newsroom, Protecting Patient Access to Integrated GI Care in the Independent Setting, Resources

Member Spotlight

Adult Gastroenterology Associates is a single-specialty GI and hepatology practice serving Tulsa and much of Northeastern Oklahoma, with physicians who specialize in colon cancer screening, treatment of GERD, IBD, and treatment of diseases of the liver and pancreas.

Learn more at:
www.tulsagastro.com

Become a Member

    Is your practice interested in promoting and preserving accessible, high quality and cost-efficient care in the independent GI medical setting? Contact us today about joining DHPA.

    Recent News

    • DHPA Recommends MACRA Improvements to Bipartisan Group of U.S. Representatives

    • New Study in Gastro Journal: GI Patients Consider Telehealth to be the Same as In-Person Visits

    • DHPA Comment Letter on OPPS/ASC Proposed Rule for Calendar Year 2023

    • DHPA Comment Letter on MPFS Proposed Rule for Calendar Year 2023

    • Webinar: Supporting Career Development for Women in GI

    • Reducing the Burden of Colorectal Cancer: AGA Position Statements

    • Dr. Latha Alaparthi Named President & Board Chair of DHPA

    • Independent Healthcare Grants and Charitable Donations (Abbvie)

    • Community Grant Program (Walmart Foundation)

    Digestive Health Physicians Association, Inc.
    10770 Columbia Pike, Suite 400
    Silver Spring, Maryland, 20901
    © 2020 DHPA

    Follow @DHPAnews
    Tweets by DHPAnews

    Copyright © 2023 · Executive Pro Theme on Genesis Framework · WordPress · Log in