House Panels Take Steps to Speed Patient Access to Medical Innovation

On January 27, 2015, the House Energy and Commerce Committee released its “21st Century Cures Act” discussion draft, the product of a year-long, bipartisan effort by the Committee to accelerate the pace of medical cures in the United States. The nearly 400-page bill addresses a wide range of topics, including, among many other things: the drug and device approval processes; clinical trials; Medicare coverage, payment, and coding; drug safety; and other proposals intended to streamline medical technology regulations across government. The Committee invites interested stakeholders to submit specific suggestions about how to improve the legislation; no deadline is specified.

In a related development, on January 29, the Senate Health, Education, Labor and Pensions (HELP) Committee launched its own initiative to examine and reform public policies in order to speed patient access to safe and effective medical products and treatments. To kick off this effort, the HELP Committee released a report entitled “Innovation for Healthier Americans: Identifying Opportunities for Meaningful Reform to Our Nation’s Medical Product Discovery and Development.” The report seeks feedback on a series of questions on ways to decrease the time and costs associated with bringing medical products to patients, including questions related to: more effectively targeting government resources; evaluating public-private partnerships; promoting biomedical research; streamlining clinical trial requirements; modernizing Food and Drug Administration medical product approval processes; and harmonizing US regulations with international standards. Feedback is requested by February 23, 2015. The Committee also intends to hold a series of hearings on issues raised in the report. 

GAO Examines Geographic Variation in Private Payer Spending on High-Cost Procedures

On January 28, 2015, the Government Accountability Office (GAO) released a report entitled “Private Health Insurance: Geographic Variation in Spending for Certain High-Cost Procedures Driven by Inpatient Prices.” In the report, the GAO examines: (1) how spending per episode of care for certain high-cost procedures varies across geographic areas for private payers, and (2) how the mix of service types, and the volume, intensity, and price of services contribute to variation in episode spending across geographic areas for private payers. Specifically, using a large private sector claims database, GAO examined 2009 and 2010 spending by metropolitan statistical areas (MSA) for episodes of care for three commonly performed inpatient procedures -- coronary stent placement, laparoscopic appendectomy, and total hip replacement. The GAO examined spending by service category: hospital inpatient, hospital outpatient, post-discharge, professional, and ancillary services. For inpatient and professional services, GAO examined the volume, intensity, and price of services.

According to the GAO, its investigation found that spending for an episode of care in the private sector varied across MSAs for the three procedures, even after GAO adjusted for geographic differences in the cost of doing business and differences in enrollee demographics and health status. MSAs in the highest-spending quintile had average adjusted episode spending that was 74% to 94% higher than MSAs in the lowest-spending quintile, depending on the procedure. The price of the initial hospital inpatient admission was the key driver of differences in episode spending in high- and low-spending MSAs. Professional services (office visits and other services provided by a physician or other health professional) were the second largest contributor to geographic differences, but accounted for only 7% or less of the difference in total episode spending between MSAs in the lowest- and highest-spending quintiles. The report does not include recommendations, and GAO notes that its findings may not be generalizable to all private insurers due to data limitations. 

Congressional Health Policy Hearings & Markups

On January 27, 2015, the House Energy and Commerce Subcommittee on Health held a hearing on bipartisan public health legislation, including:

  • Ensuring Patient Access to Effective Drug Enforcement Act (to improve enforcement efforts regarding prescription drug diversion and abuse);
  • Improving Regulatory Transparency for New Medical Therapies Act (to amend the Controlled Substances Act to improve the efficiency, transparency, and consistency of the Drug Enforcement Agency’s process for scheduling new drugs);
  • Veteran Emergency Medical Technician Support Act (to provide demonstration grants to states with a shortage of emergency medical technicians (EMTs) to streamline licensing requirements for military veteran EMTs);
  • Trauma Systems and Regionalization of Emergency Care Reauthorization Act (to reauthorize grants supporting state and rural development of trauma systems and authorize new regionalized emergency care model pilot projects); a bill to reauthorize language from the Public Health Service Act to fund trauma care centers; and
  • National All Schedules Prescription Electronic Reporting (NASPER) Reauthorization Act (to reauthorize programs to support state prescription drug monitoring programs).

On January 28, 2015, the Senate Finance Committee unanimously approved H.R. 22, the “Hire More Heroes Act," which is intended to allow businesses to hire veterans without them counting as a full-time employee under the Affordable Care Act (ACA) if the veteran already has medical coverage through the TRICARE program or the Veterans Administration. The House approved the legislation earlier this month.

Looking ahead, the following hearings are scheduled next week:

CMS Adds Star Ratings to Dialysis Facility Compare

On January 22, 2015, the Centers for Medicare & Medicaid Services (CMS) added star ratings to the Dialysis Facility Compare (DFC) website, with a one- to five-star rating assigned based on performance on nine quality measures. CMS plans to update the star ratings annually beginning in October 2015. CMS also announced plans to add the dialysis facility Standardized Readmission Ratio (SRR) to the data available on the DFC website, although it will not be included in the star rating at this time. 

OIG Examines CMS Payments to Hospitals for Clinic Visits

The HHS Office of Inspector General (OIG) estimates that CMS made $4.6 million in incorrect Medicare outpatient payments to hospitals for established patients’ clinic visits in 2012. According to the OIG, hospitals attributed the incorrect payments to staff making clerical and programing errors, not verifying whether the patient was registered as an inpatient or outpatient of the hospital within the past 3 years (and thus considered an established rather than new patient), not following hospital procedures, not fully understanding Medicare billing requirements for clinic visits, and relying on the code that the treating physician billed for that visit. The OIG also observes that CMS does not have edits in place to identify Medicare payments for patients who were already registered at a facility. The OIG recommends that CMS work with its Medicare administrative contractors to recover identified incorrect payments and resolve additional potential overpayments to the extent feasible. For more information, see the full report, “CMS Did Not Always Correctly Make Clinic Visit Payments to Hospitals During Calendar Year 2012.” 

OIG Questions Potentially Duplicative Hospital Quality Improvement Efforts

The OIG recently issued a report that examined the extent to which Quality Improvement Organizations (QIOs) duplicate other CMS hospital quality improvement efforts, particularly Hospital Engagement Networks (HENs) and the Community-Based Care Transitions Program (CCTP). Based on a questionnaire sent to a random sample of 410 Medicare hospitals, more than half of responding hospitals reported that that they participated with QIOs on quality improvement projects in 2013, but the majority also worked with other federally-funded and non-federally-funded entities on the same topics. The OIG observes that the overlap in the CMS quality improvement efforts raises concerns about duplication of efforts and complicates attributing quality improvements to any one effort. The OIG therefore recommends that CMS: (1) take steps to coordinate and reduce overlap between the QIO program and CMS’s other quality improvement efforts; and (2) determine the relative contribution of each of its quality improvement efforts. CMS concurred with the recommendations, which were set forth in the report, “Quality Improvement Organizations Provide Support to More Than Half of Hospitals but Overlap with Other Quality Improvement Programs.” 

OIG Responds to Hospital Compliance Review Objections

The OIG has defended its hospital compliance review policies in response to objections raised by the American Hospital Association (AHA). Specifically, a January 15, 2015 OIG letter addresses four main areas of AHA concern about the OIG’s application of Medicare rules and policies: (1) the need for a physician order, (2) the treatment of canceled surgeries, (3) the rebilling of Medicare Part A claims under Part B, and (4) the review of claims beyond the statute of limitations. While the OIG letter cites legal authorities supporting its policies, the OIG did announce that given the “dynamic landscape” of Medicare inpatient short-stay policy, it has voluntarily suspended reviews of inpatient short-stay claims after October 1, 2013, consistent with the moratorium placed on the recovery audit contractors.

CMS Schedules Provider Calls on Medicare Payment, Quality, Coding & Program Integrity Topics

CMS has scheduled a series of provider calls in February and March on the following topics:

FTC/DOJ Workshop on Health Care Competition (Feb. 24).

On February 24, 2015, the Federal Trade Commission and the Department of Justice Antitrust Division will hold a public workshop on health care provider organization and payment model developments that may affect competition in the provision of health care services. Topics for discussion include: accountable care organizations; alternatives to traditional fee-for-service payment models; trends in provider consolidation; provider network and benefit design strategies; and health insurance exchanges.  The government also will accept comments on specific questions related to health care competition until April 30, 2015.

HHS Sets Ambitious Goals for Medicare Quality/Value-Based Purchasing, Alternative Payment Models

Today HHS Secretary Sylvia M. Burwell announced ambitious plans to move from “volume to value in Medicare payments” by accelerating the share of Medicare fee-for-service (FFS) payments that are tied to quality and value and reimbursed through alternative payment models. The first goal in the initiative is for 30% of Medicare provider payments to be in alternative payment models – such as accountable care organizations, medical homes, bundled payments -- by 2016 (up from about 20% today). The goal would rise to 50% by 2018.

Under the second component of the plan, HHS seeks to tie 85% of Medicare FFS payments to quality by 2016, rising to 90% in 2018. In addition to the various alternative payment models, such quality programs include the Hospital Value Based Purchasing Program, the Hospital Readmissions Reduction Programs, and the Physician Value-Based Modifier.

To extend these value initiatives beyond Medicare and reach a “critical mass of payers,” HHS is announcing the establishment of the Health Care Payment Learning and Action Network to coordinate the efforts of the private, public and non-profit sectors, including private payers, large employers, providers, consumers, and state and federal partners. The goal of the Learning and Action Network is to facilitate joint implementation and expansion of new models of payment and care delivery; collaborate to generate evidence and share approaches; develop common approaches to core issues such as beneficiary attribution, financial models, benchmarking, and risk adjustment; and create implementation guides for payers and purchasers. The Network will hold its first meeting in March 2015.

For additional details, see Secretary Burwell’s “Perspectives” article in the New England Journal of Medicine.

Medicare DMEPOS Competitive Bidding Window is Now Open

The bidding window is now open for the Medicare Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Competitive Bidding Program Round 2 Recompete and the National Mail-Order Recompete for diabetic testing supplies. Bids will be accepted until March 25, 2015. Other key dates to note:

  • Registration to bid will close on February 17, 2015. Only suppliers that have registered and received a user ID and password will be eligible to submit bids.
  • The deadline to participate in the covered document review process is February 23, 2015. Under this process, suppliers may submit their required hardcopy financial documents to the Competitive Bidding Implementation Contractor (CBIC) in advance of the close of the bid window; suppliers will be notified if any individual financial documents are missing and have an opportunity to submit the missing documents.

Additional details are available at the CBIC web site.  

MedPAC Voices Concerns about Growing Volume, Burden of Medicare Quality Measures

In December 2014, CMS released a 329-page list of quality measures under consideration for the Medicare program. In a January 13, 2015 comment letter, MedPAC observes that volume of measures under consideration “reinforces our concerns that Medicare’s provider-level measurement activities are accelerating without regard to the costs or benefits of an ever-increasing number of measures.” MedPAC suggests that CMS is “relying on too many clinical process measures that are, at best, weakly correlated with health outcomes.” Moreover, including numerous process measures could reinforce “undesirable payment incentives in FFS Medicare to increase the volume of services and is overly burdensome on providers to report, while yielding limited information to support clinical improvement or beneficiary choice.” While acknowledging that CMS includes more measures than will be adopted in order to solicit comments, MedPAC urges CMS to “carefully consider whether each additional measure would simply reinforce or exacerbate the current system’s problems.”

The following is MedPAC’s count of measures under consideration (note that the largest number of measures under review this year apply to accountable care organizations):

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New Postings on the Reed Smith Health Industry Washington Watch Blog

The Reed Smith Health Industry Washington Watch blog has been updated to report on recent health policy developments, including the following:

  • Regulatory Developments. The Obama Administration has issued proposed rules on Affordable Care Act (ACA) summary of benefits and coverage and uniform glossary requirements and excepted benefits/wraparound coverage. The OIG has published its annual solicitation of recommendations for new anti-kickback statute safe harbor provisions and topics for special fraud alerts. Stage 3 meaningful use criteria and health information technology certification proposed rules are in the pipeline. CMS has published Medicare quality improvement organization criteria. FDA regulations/notices have addressed Drug Supply Chain Security Act compliance, electronic distribution of prescription drug biological prescribing information, and direct-to-consumer television ads for prescription drugs. The IRS has issued additional ACA requirements for tax-exempt hospitals.
  • Other HHS Developments. CMS has adjusted the first quarter 2015 Medicare physician fee schedule conversion factor, and it has made announcements regarding provider timeframes for responding to pre-payment review documentation requests and recovery audit contracts. OIG reports have examined hospice care in assisted living facilities and the appropriateness of Medicare ophthalmology claims.
  • Legislative Developments. The House has approved bills to modify certain ACA rules for employers related to part-time workers and veterans. President Obama signed into law a previously-reported tax bill with Medicare provisions and an Ebola treatment/vaccine bill. A House hearing next week will focus on SGR reform.
  • Health Industry Events. MedPAC is meeting to discuss Medicare payment policy, the FDA is holding a workshop on regulatory oversight of next generation sequencing diagnostic tests, and CMS is events will focus on the Open Payments database and hospital outpatient payment policy.
  • @ReedSmithHealth is on Twitter. For the latest health policy news, follow us at @ReedSmithHealth.

House E&C Committee Schedules SGR Hearing (Jan. 21 & 22)

The House Energy and Commerce Subcommittee on Health has scheduled a two-day hearing for January 21 and 22 to discuss how to pass Sustainable Growth Rate (SGR) reform legislation before the current patch expires at the end of March 2015.

OIG Questions Incentives for Hospice Care in Assisted Living Facilities

Today the OIG issued a report examining the growing use of Medicare hospice care in the assisted living facility (ALF) setting. According to the OIG, Medicare payments for hospice care in ALFs grew by more than 119% from 2007 to 2012, compared to a 38% increase in spending for hospice care provided in other settings. The OIG also reports that hospices provided care for longer periods and received higher Medicare payments for beneficiaries in ALFs compared to other settings, even though hospice beneficiaries in ALFs often had diagnoses that typically require less complex care. The median amount Medicare paid for-profit hospices for care in ALFs during the five-year period was $18,261 per beneficiary, compared to $13,941 for nonprofit hospices. The OIG contends that its findings suggest that the current payment system includes financial incentives that could encourage hospices to target beneficiaries in ALFs.

The OIG recommends that CMS take its findings into account as CMS undertakes hospice reforms mandated by the Affordable Care Act (ACA). Specifically, the OIG recommends that CMS: (1) reform payments to reduce the incentive for hospices to target beneficiaries with certain diagnoses and those likely to have long stays, (2) target certain hospices for review, (3) establish claims-based quality measures, (4) make hospice data publicly available for beneficiaries, and (5) educate hospices regarding how they compare to their peers. CMS concurred with these recommendations.

Stage 3 EHR Incentive Program, Health IT Certification Rules at OMB

HHS has sent to the White House Office of Management and Budget (OMB) for final regulatory clearance a proposed rule on Stage 3 meaningful use criteria for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. The Stage 3 rule will focus on advanced use of EHR technology to promote improved outcomes for patients, and it propose changes to the reporting period, timelines, and structure of the program, including providing a single definition of meaningful use. Likewise, HHS is seeking review of proposed rule that would, among other things, establish a new 2015 Edition Base EHR definition and modify the ONC Health Information Technology (IT) Certification Program to make it more broadly applicable to other types of health IT health care settings and programs. The rules are not available yet, but could be approved for publication in the Federal Register at any time.

House Approves Bills to Modify ACA Rules for Employers Related to Part-Time Workers, Veterans

On January 8, 2015, the House of Representatives approved H.R. 30, the “Save American Workers Act.”  The legislation would amend the ACA’s definition of “full-time employee” for purposes of the requirement that certain employers provide health care coverage for their full-time employees. Specifically, the bill, which was approved on a 252 to 172 vote, would define full-time employee as an employee who is employed on average at least 40 hours of service a week, rather than the ACA’s 30 hours.  The Administration has promised to veto the legislation if it reaches the President’s desk.

This vote followed unanimous House passage of a separate bill, H.R. 22, the “Hire More Heroes Act of 2015.” H.R. 22 is intended to encourage businesses to hire veterans by permitting an employer, for purposes of determining whether the employer is an applicable large employer and thus required to provide health care coverage to its employees under the ACA, to exclude employees who have health coverage under TRICARE or the Veterans Administration.

Both bills are awaiting Senate consideration.

CMS Guidance on Provider Timeframes for Responding to Additional Documentation Requests

CMS has updated the Medicare Program Integrity Manual to clarify that providers and suppliers have 45 days to produce documents in response to a pre-payment review Additional Documentation Request (ADR) issued by a Medicare Administrative Contractor (MAC) or Zone Program Integrity Contractors (ZPIC). MAC and ZPIC reviewers are instructed not to grant extensions to providers who need more time to comply with such requests; instead, claims must be denied if the requested documentation is not received by day 46.

CMS Announces DMEPOS/Home Health/Hospice RAC, Improvements to RAC Process

CMS has announced that it has awarded the Region 5 Recovery Audit contract to Connolly, LLC (although the General Accounting Office subsequently reported that a bid protest has been filed regarding this award). The purpose of this contract will be to identify improper Medicare payments for durable medical equipment (DME), orthotics, prosthetics, and supplies and home health/hospice (HH/H) claims and work with CMS and the DME and HH/H MACs to adjust claims to recoup overpayments and pay underpayments. CMS observes that this award marks the beginning of the new Recovery Audit contracts, and it is the first contract to incorporate a series of changes intended to reduce the provider burden and increase program transparency (e.g., ADR limits, RAC accuracy threshold).

Electronic Distribution of Prescribing Information for Prescription Drugs & Biologicals

The FDA published a proposed rule on December 18, 2014 that would require electronic distribution of the prescribing information intended for health care professionals, which is currently distributed in paper form on or within the prescription drug or biological product packaging. FDA also is proposing that prescribing information intended for health care professionals will no longer be permitted to be distributed in paper form with the package from which a prescription drug or biological product is dispensed, except as provided by this regulation. According to the FDA, its proposal is intended to facilitate the distribution of updated prescribing information as new information becomes available or prescribing information changes are made, and to ensure that “the most current prescribing information for distributed prescription drugs will be available and readily accessible to health care professionals at the time of clinical decisionmaking and dispensing.” Comments on the proposed rule will be accepted until March 18, 2015.

OIG Examines Appropriateness of Medicare Ophthalmology Claims

The OIG recently assessed the appropriateness of claims submitted by providers for screening for, diagnosing, evaluating, or treating cataracts, wet age related macular degeneration (wet AMD), and glaucoma in 2012. The OIG estimates that Medicare paid $22 million for ophthalmology claims in 2012 that were potentially inappropriate, according to national and local coverage requirements, although the OIG cautions that it did not review the medical records for any claims to determine if exceptions to the coverage requirements were documented and appropriate. The OIG recommends that CMS strengthen claims processing edits, and determine the appropriateness of ophthalmology claims identified in the report, and take appropriate action. CMS concurred with the recommendations in the report, “Medicare Paid $22 Million in 2012 for Potentially Inappropriate Ophthalmology Claims.”

CMS Publishes Medicare QIO Criteria

CMS has published notices setting forth the criteria it will use to evaluate the effectiveness and efficiency of Quality Innovation Network (QIN) and Beneficiary and Family Centered Care (BFCC) Quality Improvement Organizations (QIOs) that entered into contracts with CMS in 2014.

IRS Issues Additional ACA Requirements for Tax-Exempt Hospitals

On December 31, 2014, the IRS published final regulations providing guidance on the community health needs assessment and financial assistance policy requirements for charitable hospitals under the ACA. The regulations address the entities that must meet these requirements, related reporting obligations, and the consequences for failing to satisfy these ACA requirements. The regulations apply to taxable years beginning one year after December 29, 2014.

President Signs Tax Bill with Medicare Provisions, Ebola Treatment/Vaccine Bill

In December 2014, President Obama signed into a law H.R. 5771, a tax extender bill that includes the “Achieving a Better Life Experience (ABLE) Act of 2014.” As discussed in a previous post, the law, P.L. 113-295, includes three Medicare provisions to finance the ABLE Act: revisions to payment adjustments for Medicare physician fee schedule misvalued services, limits on Medicare coverage of vacuum erection systems, and an additional delay in implementation of oral-only end stage renal disease (ESRD)-related drugs in the ESRD PPS.  President Obama also has signed into law S. 2917/P.L. 113-233, which adds Ebola to the FDA’s priority review voucher program.

FDA One Step Closer to New Direct-To-Consumer Television Ad Requirements

This post was written by Jennifer Pike.

Last February, the Food and Drug Administration (FDA) asked for public feedback on a proposed research study related to prescription drug television advertisements. In a notice published in the Federal Register on January 13, 2015, FDA announced its intention to continue to move forward with the proposed study. Specifically, the notice announced that the Agency had submitted a proposed collection of information to the Office of Management and Budget (OMB) for review and approval. The notice describes the general framework for the study, entitled “Disclosure Regarding Additional Risks in Direct-to-Consumer (DTC) Prescription Drug Television (TV) Advertisements (Ads),” and it provides FDA’s response to the 55 comments it received regarding its February 2014 notice.

Current FDA regulations (21 CFR § 202.1) require that TV and radio ads present a product’s major risks in audio, or audio and visual parts of the ads (“major statements”). FDA is concerned that these major statements are too long, resulting in reduced consumer comprehension, minimization of important risk information, and, potentially, therapeutic noncompliance due to fear of side effects. At the same time, and in conflict with the above, FDA is concerned that DTC TV ads do not include adequate risk information. FDA believes that providing limited risk information in ads will promote improved consumer perception and understanding of serious and actionable drug risks.

OMB is accepting comments on the collection of information until February 12, 2015.

CMS Open Payments Question & Answer Session (Jan. 15)

On January 15, 2015, CMS is hosting an Open Payments Question & Answer Session, at which the CMS “Open Payments team” will be available to respond to questions about the data refresh and the upcoming 2014 Open Payments program year.  CMS intends to conduct these sessions monthly in the future.

MedPAC Meeting on Medicare Policies (Jan. 15-16)

On January 15-16, 2015, the Medicare Payment Advisory Commission (MedPAC) is meeting to discuss a number of Medicare topics, including, among others: post-acute care trends; payment updates for a number of provider types; relative costs of Medicare Advantage, accountable care organizations, and fee-for-service Medicare; hospital short stay policy; and quality measurement. 

CMS Revises Down 1st Quarter 2015 Medicare Physician Fee Schedule (MPFS) Conversion Factor

CMS has posted a January 2015 release of the National Physician Fee Schedule Relative Value File, reflecting a conversion factor (CF) of $35.7547 – down slightly from the $35.8013 included in the 2015 final MPFS rule published on November 12, 2014.  CMS is expected to publish a notice explaining the reasons for the revised CF.  CMS had previously announced that it is holding Medicare physician claims for services furnished during the first two weeks of 2015 because of unspecified errors found in the MPFS final rule.  The claims hold is not expected to actually disrupt cash flow since clean electronic claims are not processed for 14 days anyway.

Note that the new CF applies only to services provided during the first three months of 2015, as a result of a temporary patch included in the Protecting Access to Medicare Act (PAMA) of 2014.  On April 1, 2015, the conversion factor is scheduled to be adjusted according to the statutory Sustainable Growth Rate (SGR) formula, resulting in an estimated 21.2% reduction -- unless Congress steps in and establishes an alternative conversion factor or otherwise reforms the SGR formula. Congress is expected to attempt to adopt a measure to prevent the scheduled April 1 SGR reduction from taking place.

Administration Issues Proposed Rules on ACA Summary of Benefits and Coverage, Excepted Benefits/Wraparound Coverage

On December 30, 2014, the Internal Revenue Service (IRS), the Employee Benefits Security Administration (EBSA), and the Centers for Medicare & Medicaid Services (CMS) published a proposed rule that would revise Affordable Care Act (ACA) summary of benefits and coverage (SBC) and uniform glossary requirements for group health plans and health insurance coverage. The changes, which would modify a February 14, 2012 rulemaking, are intended to help plans and individuals better understand their health coverage options and compare plans. For instance, the proposed rule would add another coverage example to the SBC to illustrate costs for consumers, streamline the SBC, and revise the uniform glossary that helps consumers understand insurance terms. If finalized, the new requirements would be implemented for plan years beginning on or after September 1, 2015. Comments on the proposed changes are due by March 2, 2015.  The Departments also issued revised draft SBC template, instructions, and supplemental materials.

Separately, the agencies published a proposed rule on December 23, 2014 that would amend the definition of excepted benefits to allow group health plan sponsors, in limited circumstances, to offer wraparound coverage to individuals who are purchasing individual health insurance in the private market, including through the ACA Health Insurance Marketplace. The rule proposes the following pilot programs for wraparound coverage: a pilot allowing wraparound benefits only for Multi-State Plans in the Marketplace, and a pilot allowing wraparound benefits for part-time workers or retirees who enroll in an individual market plan. There are several significant conditions and limitations to this type of coverage. This type of wraparound coverage could be offered as excepted benefits to coverage that is first offered no later than December 31, 2017 and that ends on the later of: (1) the date that is three years after the date wraparound coverage is first offered; or (2) the date on which the last collective bargaining agreement relating to the plan terminates after the date wraparound coverage is first offered.  Comments will be accepted until January 22, 2015.

CMS Call: Medicare Quality Reporting Programs: Data Submission Process (Jan. 13)

On January 13, 2015, CMS is hosting a national provider call to provide an overview of the 2014 submission process for Medicare quality reporting programs, including the Physician Quality Reporting System (PQRS), Value-Based Payment Modifier, and the Electronic Health Record Incentive Program. This session will discuss how eligible professionals and PQRS group practices can earn the 2014 PQRS incentive and avoid the 2016 negative PQRS payment adjustment through these reporting mechanisms.