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The Alliance Advocates Relief from Regulatory Burden to Improve Patient Care
In July, the House Ways and Means Health Subcommittee announced a new initiative aimed at delivering relief from regulations and mandates under the Medicare program that stand in the way of delivering better care for Medicare beneficiaries. Under the multi-stage Medicare Red Tape Relief Initiative, the Committee is seeking to identify opportunities to reduce legislative and regulatory burdens on Medicare providers.

Under the first stage, the Committee asked for feedback regarding:
  • How Congress can deliver statutory relief from the mandates established in law through legislative authority, and
  • How Congress can work with Health and Human Services (HHS), and Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma to deliver regulatory relief through administrative action.
The Alliance of Specialty Medicine has been active in identifying burden and recommending solutions to provide relief from mandates facing specialists, not only in the Medicare program but also across federal health care programs more broadly. In response to this call for feedback, the Alliance prepared 11 submissions addressing burdens established under both regulatory and statutory mandates. These addressed the following topics, listed in priority order:
  • Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Transition Policies
  • Sunset Quality Programs - Physician Quality Reporting System (PQRS), Electronic Health Record (EHR) Incentive Program, and Value-Based Payment Modifier
  • Drug Compounding
  • Prior Authorization
  • MIPS Adjustments to Part B Drugs
  • Delaying 2015 Edition Certified Electronic Health Record Technology
  • Imaging Appropriate Use Criteria (AUC) Program
  • Narrow Networks
  • Program Integrity Initiatives
  • Two Midnights Rule
  • MIPS Virtual Groups
These submissions are focused on Medicare requirements that have a significant and often disproportionate impact on specialists and subspecialists. For example, several of the submissions address requirements that affect physician payment under the Merit-Based Incentive Payment System (MIPS), which was established under MACRA. In its submissions, the Alliance called on Congress to provide greater flexibility to the Secretary regarding MIPS scoring to ease the transition to MIPS, ensure that MIPS payment adjustments do not apply to Part B drugs, prevent the application of inappropriate standards regarding the use of certified EHR technology, and increase flexibility in determining which clinicians and groups can align to form Virtual Groups for MIPS reporting. These changes would increase CMS’ ability to accurately assess clinicians and adjust payments on the care they deliver.

The Alliance also sought relief from burdensome programs, given the need to focus on preparation for MIPS. For example, the Alliance requested relief from penalties under legacy physician reporting and quality programs, including PQRS, the EHR Incentive Program, and the Value-Based Payment Modifier. The Alliance also requested that Congress terminate the Imaging Appropriate Use Criteria (AUC) Program, which is excessively burdensome and duplicative of MIPS in seeking to promote high quality, efficient care.

Other submissions focused on issues that prevent access to specialty care, including narrow plan networks and restrictions on in-office drug compounding, as well as barriers that prevent clinicians from fully exercising their clinical judgment, including prior authorization and the Medicare Two Midnights rule for inpatient admissions. The Alliance also requested administrative relief from CMS’ duplicative, non-transparent, and overly punitive approach to program integrity through the adoption of concrete steps that would increase certainty and reduce burden for clinicians, while also allowing CMS to continue protecting against fraud, waste, and abuse.

As a whole, these recommended changes will increase access to care, as well as provide clinicians greater ability to apply their clinical judgement and focus on the delivery of high-quality care for patients, rather than worry about paperwork, administrative barriers, and potentially significant payment reductions.

The Committee requested that feedback on this first stage be provided by August 25, 2017. Under Stage 2, the Committee will host roundtables with stakeholders across the country to continue conversations and identify solutions. Finally, Stage 3 will entail Congress taking action based on feedback from stakeholders.

The Alliance of Specialty Medicine looks forward to ongoing engagement with the Committee as this initiative progresses in order to support specialists and their patients.

Alliance Advocacy Fly In. July 16th-18th, 2018. Liaison Hotel, Washington, DC

NOTE: Participation in Alliance events is by invitation-only, with some exceptions. To learn more about how you or your organization can participate, please contact your organization's staff liaison to the Alliance or email us at info@specialtydocs.org.


"Let Physicians Treat the Patient - Not the Potential Lawsuit" The Hill.
- June 14, 2017.

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Join the most powerful group of specialty physicians!
Joining forces with specialty doctors from across the country helps amplify the concerns specialty doctors share. By working together, specialty medical organizations can work more effectively to influence health care policy and ensure our primary goal: to continue to provide our patients the optimal care they need. As a part of the non-partisan umbrella organization representing all of specialty medicine, your organization will:

  • Promote specialty specific issues as part of a larger coalition, increasing visibility and understanding of issues.
  • Help increase exposure for specialty medical care.
  • Gain access to insider information, background materials and research on health policy initiatives and the political landscape.
  • Receive expert analysis on proposed legislation.
  • Caucus with other specialty organizations at the AMA House of Delegates and other forums to promote key issues that are important to specialty physicians.
  • Coordinate physician and patient grassroots efforts through a large and robust network.
  • Participate in future Alliance Fly-In events in Washington, D.C. Past events have included Capitol Hill visits and presentations by health policy experts.
For information on joining the Alliance of Specialty Medicine, visit our website at www.specialtydocs.org or contact Vicki Hart at vhart@hhs.com

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