Health Policy
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Healthcare is a more dynamic market and now more than ever urgent care professionals need to stay informed on key issues affecting their patients' care. Be sure to stay up-to-date on health policy issues and the potential impact they may have on the urgent care industry by checking out the resources below.

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UCA, with the Health and Public Policy Committee Comments on Proposed E/M Changes and Urgent Care Measures (September 11, 2018): On September 10, the Urgent Care Association (UCA), with input from your Health and Public Policy Committee, submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the CY 2019 Medicare Physician Fee Schedule Proposed Rule.  The rule includes changes to Medicare payment policy and participation requirements for the Quality Payment Program (QPP) for 2019.

One of the most consequential provisions of the rule is a proposal to change the way clinicians document for Evaluation and Management (E/M) visits and how CMS reimburses for those services.  Under its proposal, CMS would continue to differentiate between new and established patients but would collapse Levels 2 through 5 E/M codes into a singular payment.  The effect of a blended payment is higher payment rates for Level 2 and 3 visits and lower payments for Level 4 and 5 visits.  CMS also proposed the creation of add-on codes that could be used for primary care and complex patients, which seems to suggest that CMS collapsed payment rates are imperfect.

In its comments, UCA expressed support for CMS proposals to reduce E/M documentation redundancy but asked CMS to not finalize its proposed E/M coding and payment changes.  Instead, UCA asked that CMS allow for a more deliberative process, including the development of alternative proposals by an American Medical Association-convened workgroup of coding and valuation experts.  Like most of medicine, whether urgent care providers would benefit under a blended E/M payment scheme is highly dependent on mix of patients and coding practices.

UCA also commented in the letter on proposed changes to the QPP for the 2019 performance year. UCA expressed support for CMS proposal to create a set of urgent care measures from which urgent care providers could choose from for meeting the requirements of the Quality component of the Merit-based Incentive Payment System (MIPS). UCA, alongside the College of Urgent Care Medicine, called on CMS earlier this year to create an urgent care specialty measure set. Even if the urgent care measure set is finalized, urgent care providers could still choose any MIPS measure on which to report. 

UCA also gave its support for a third criterion providing fewer than 200 covered professional services to Part B patients for clinicians to qualify for the low-volume threshold and earn an exemption from MIPS. CMS is also proposing a new policy that allows practices to opt-in to participate in the MIPS program or create virtual groups if they meet or exceed one or two but not all of the low-volume threshold elements.

Publication of a final rule is expected in early November.  

Medicare Proposed Fee Schedule Released: Urgent Care Specialty Measure Set Included & Big Changes for E&M (July 19, 2018): On July 12, the CY 2019 Medicare Physician Fee Schedule (PFS) proposed rule was released, which also includes proposed changes to the Quality Payment Program (QPP) for the 2019 performance year.  CMS is proposing a new urgent care specialty measure set.  The measure set, which includes 15 measures, was requested by the College of Urgent Care Medicine (CUCM) and Urgent Care Association (UCA).  Eleven of 12 measures proposed by CUCM and UCA were accepted. The creation of a measure set will serve to help urgent care providers with the selection of measures when fulfilling the quality component of the Merit-Based Incentive Payment System (MIPS).  The measure set also creates a distinction between family and emergency medicine.

Among the most consequential proposals in the rule is the creation a single payment amount for office/outpatient Evaluation and Management (E/M) visit levels 2 through 5. As a corollary to the proposed payment changes, CMS is proposing to apply a minimum documentation standard where, for the purposes of PFS payment for an office/outpatient E/M visit, practitioners would only need to meet documentation requirements currently associated with a level 2 visit for history, exam and/or Medical Decision Making (MDM) (except when using time to document the service). The proposed payment changes are budget neutral which will result in a redistribution of dollars among primary and specialty care.

Public comment on the proposed rule will be accepted until September 10.

Testimony by UCA to Reduce Health Care Costs (June 28, 2018): Reducing the cost of health care in the United States requires an understanding of health care cost drivers and empowering patients to make wise health care decisions. The Urgent Care Association (UCA) appreciates the opportunity to lend its voice to this discussions as all Americans should have access to affordable and comprehensive health care coverage. The reality is, however, that health care affordability requires attacking the cost drivers in our system without compromising access or quality. One cost driver is health system failure to incentivize site appropriate health care and the inability of consumers to make informed decisions on where to access care because transparency is lacking. Please read the testimony further here.

Value Based Reimbursement State by State: A 50-State Review of Value-Based Payment Innovation (June 21, 2018): The Payer Relations Committee discussed this item on a recent call and how it connects them with the Health and Public Policy Committee. This can serve as a valuable resource to UCA members as this report seeks to shed light on this other work through an examination of state-level value-based payment initiatives underway across America. Overall, five states stand out for the breadth of their initiatives, their embrace of payment models that involve shared risk, and their willingness to test innovative strategies. Please read the full report here.

UCAOA Offers Support on Pending MO Bone Marrow Bill (April 6, 2018): In a letter to members of the Missouri General Assembly, UCAOA offered support of the pending legislation that would encourage, but not require, primary care providers and urgent care physicians to inquire of new patients whether they are registered with the bone marrow registry. If a patient is not registered, the health care provider would provide information about the bone marrow registry. In its letter of support, UCAOA emphasized the importance of giving health care providers flexibility to voluntarily support initiatives to increase the number of potential bone marrow donors. The legislation has passed the Missouri House is now pending in the Senate. Send your thoughts, ideas and experiences to Nirja Shah at nshah@ucaoa.org.

Senators Solicit Views on Price Transparency; UCAOA Responds (April 3, 2018): Sens. Bill Cassidy, M.D. (R-LA), Michael Bennet (D-CO), Chuck Grassley (R-IA), Tom Carper (D-DE), Todd Young (R-IN), and Claire McCaskill (D-MO) are seeking feedback from the health care and patient communities as they develop legislation to improve price transparency in the health care market. In response to the solicitation, UCAOA submitted comments that the lack of price and information transparency is a contributor to hospital emergency department overuse. The Association also highlighted that many consumers dont know the difference on when to seek care at a free-standing emergency department versus an urgent care center and the associated costs a distinction that may not become apparently until after a patient received a bill for care provided in a free-standing emergency department that includes a facility charge. The Health & Public Policy Committee is interested in better understanding state-level price transparency requirements from an urgent care center perspective.  Send your thoughts, ideas and experiences to Nirja Shah at nshah@ucaoa.org.

UCA and CUCM Recommend Urgent Care Medicine Measure Set (February 15, 2018): On February 9, the Urgent Care Association (UCA) in collaboration with the College of Urgent Care Medicine (CUCM) submitted a letter to the Centers for Medicare and Medicaid Services (CMS) in response to a call for recommendations for specialty quality measure sets for the 2019 performance year of the Merit-Based Incentive Payment System (MIPS). If CMS agrees with UCA and CUCM and develops an urgent care medicine specialty set, it will help clinicians who practice in urgent care centers with the selection of applicable measures for fulfilling the quality component of MIPS. The specialty set recommended by the two societies includes 12 quality measures. However, clinicians choosing to report the urgent care medicine specialty measure set would only be obligated to report six measures, assuming the number of required measures does not change for the 2019 performance year. UCA will learn whether the urgent care medicine specialty measure set was accepted when the Quality Payment Program proposed rule is issued later this year.



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UCA State Resources: A listing of state specific resources and descriptions to help you reach out to local entities for further information.

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