CY 2016 Medicare Physician Fee Schedule Proposed Rule July 23, 2015

Transcription

1 CY 2016 Medicare Physician Fee Schedule Proposed Rule July 23, , AAMC-UHC-FPSC Page 1

2 Audio: Housekeeping You will hear the audio through your computer speakers. Please make sure your computer speakers are on and the sound is turned up. If you still have no sound once the webinar starts, please click on the audio broadcast icon ( ) located in the Participants Panel on the right hand side of your screen. Questions: Please use the Q&A panel located on the right hand side of your screen to submit your questions throughout the webinar. Send to All Panelists. If you experience any technical or audio issues during the webinar, please send a message through the Chat panel to AAMC Meetings. 2015, AAMC-UHC-FPSC Page 2

3 The Big Picture Payment Policies Misvalued RVUs/RVU Targets/Conversion Factors Advanced Care Planning Code Care Coordination/Collaboration Services Other Proposals of Interest Quality and Efficiency Policies 2018 Value Modifier, PQRS Physician Compare Feedback on MACRA Transition Alternative Payment models Feedback on CPCI Expansion MSSP ACO Agenda , AAMC-UHC-FPSC Page 3

4 2016 Medicare Physician Fee Schedule Proposed Rule Displayed on July 7; published in Federal Register 7/15 Supplemental materials (including RVU data) Federal-Regulation-Notices-Items/CMS P.html?DLPage=1&DLEntries=10&DLSort=2&DLSortDir=descending Comments due September 8; Final rule expected November 1 Draft comment letter distributed ~Aug 31 We are seeking your feedback on the proposals! , AAMC-UHC-FPSC Page 4

5 The Big Picture: Payment SGR is repealed, but new RVU targets could still reduce conversion factor (CF) Continuation of misvalued RVU initiatives and other reviews of RVUs Major payment changes to gastroenterology and radiation practice expenses New advanced care planning codes Discussion of care coordination, collaboration codes , AAMC-UHC-FPSC Page 5

6 The Big Picture: Quality and Efficiency Policies for 2018 PQRS and Value Modifier (VM) LAST YEAR before transition to MIPS No increase to amount at risk for VM and PQRS for large group practices VM expands to certain non-physician practitioners; excludes certain CMMI programs New PQRS Group Option: Qualified Clinical Data Registries CAHPS for PQRS only required for GPRO Web Feedback on MACRA implementation Physician Compare Benchmarks methodology part of transition to 5-star rating system Feedback on Comprehensive Primary Care Initiative Expansion , AAMC-UHC-FPSC Page 6

7 FPSC Will Be Offering Solutions To Help Members Prepare for 2016 For All FPSC Participants November Data-driven Impact Analysis Webinar on changes in the final Physician Fee Schedule December - Member-specific Medicare Impact Analyses based on changes in the final Physician Fee Schedule will be distributed For FPSC Quality & Efficiency Module Participants July 28 th Webinar on Strategic Implications of the PFS Fall Academic QRUR Benchmarking Study November/December Overview of Final 2016 PFS Implications on Quality & Efficiency Additional Networking Webinars 2015, AAMC-UHC-FPSC Page 7

8 Medicare Physician Fee Schedule Proposed Rule CY2016 PAYMENT POLICIES 2015, AAMC-UHC-FPSC Page 8

9 Payment Policies Estimate of RVU changes by specialty Conversion factor estimates/new targets for RVU reductions New advanced care planning codes Discussion re primary care services Other items of interest 2015, AAMC-UHC-FPSC Page 9

10 Path, Gastro, and RadOnc Have Largest RVU Changes CMS Projected Impact on Allowable Charges by Specialty Largest Expected Increases Independent Laboratory (+9%) Pathology (+8%) Allergy/Immunology(+1%) Dermatology (+1%) Diagnostic Testing Facility(+1%) Hand Surgery(+1%) Interventional Pain Management (+1%) Interventional Radiology (+1%) Plastic Surgery (+1%) Source: Table 45, 80 Fed. Reg. p Largest Expected Decreases Gastroenterology (-5%) Radiation Therapy Centers (-9%) Radiation Oncology (-3%) Colon and Rectal Surgery (-1%) Neurosurgery (-1%) *Estimated impact for all other specialties is 0% change Actual impact can vary based on service site and mix of services 2015, AAMC-UHC-FPSC Page 10

11 New Calculation: Targets for RVU Reductions Three years of targets to identify RVU adjustments that produce reductions in PFS expenditures Targets 2016: 1.0% reduction; 2017: 0.5% reduction; 2018: 0.5% reduction Reductions will be measured via changes to RVUs Calculation If RVU reductions< target, then PFS reduced by difference If RVU reductions > target, then no adjustment to PFS, amount over target is applied to next year s target Initial 2016 RVU reduction estimate is less than target Estimate=0.25%; target=1.0%; difference=0.75% Estimate could change with interim final RVU values 80 Fed. Reg. p , AAMC-UHC-FPSC Page 11

12 Possible Impact to Conversion Factor After Budget Neutrality Adjustments & 0.5% Update Current CF $ CMS Estimate 2016 CF $ Possible adjustments if 1% RVU reduction target is missed RVU Reductions =1% RVU Reductions = 0.25% $ $ Best Case CF Estimate No Adjustment Worst Case CF Estimate CF adjustment = 0.75% decrease 80 Fed. Reg. p Actual RVU reduction likely to fall in between these two scenarios and will published in Final Rule in early November , AAMC-UHC-FPSC Page 12

13 Advanced Care Planning (ACP) 2015, AAMC-UHC-FPSC Page 13

14 Advanced Care Planning Code (ACP) Two new CPT codes proposed to be covered under Medicare in 2016: (First 30 min in facility): $ (Each additional 30 min in facility): $75.11 Explanation and discussion of advance directives (e.g. standard forms) Face to face with patient, family members, and/or surrogate Can be billed with or without a standard E/M service should be listed separately from primary procedure Must document service is reasonable and necessary (Fed. Reg., p ) 2015, AAMC-UHC-FPSC Page 14

15 Primary Care and Care Management Services 2015, AAMC-UHC-FPSC Page 15

16 Care Management Services Two recent codes: Transitional Care Management (TCM), in 2013 Chronic Care Management (CCM), 99490, in 2015 No new proposals for CY 2016! CMS seeks comments regarding improving existing codes and creating new codes. CMS anticipates developing potential proposals to address these issues through rulemaking in 2016 for implementation in , AAMC-UHC-FPSC Page 16

17 Proposed OPPS Requirements for Chronic Care Management Services 2015 MPFS CCM Requirements 2016 OPPS CCM Requirements Clinical staff portion must have an established relationship with the patient and provide care and treatment to the patient during the course of illness. Proper documentation of informing patient and his/her authorization. Hospital must have an established relationship with the patient in one of two ways: o patient is admitted as an inpatient or, o is registered as an outpatient within last 12 months. Must document, in EMR, patient s agreement to have services provided. o Patient should be informed about 2 potential copayments Only one practitioner can furnish and be paid for providing CCM services during the calendar month Use of certified EHR technology Only one hospital can furnish and be paid for providing CCM services during the calendar month Use of certified EHR technology 2015, AAMC-UHC-FPSC Page 17

18 Improving CCM and TCM Services CMS implemented separate payment for TCM services in 2013 and for CCM services in In order to better provide these services and alleviate some of the extensive requirements CMS seeks comments on: Ways to improve beneficiary s access to TCM and CCM services Specific data on utilization of CCM codes to update changes in payment and coding (e.g. clinical status of beneficiaries, resource utilization and costs) (Fed. Reg., p ) 2015, AAMC-UHC-FPSC Page 18

19 Feedback to Improve Care Coordination Services CMS seeks feedback on adding new codes to properly reflect all of the services and resources involved with furnishing comprehensive coordinated care management. Time and Intensity Utilization of Additional Resources Factors to Address Costs of Additional Resources Overlap of Cognitive Resources (Fed. Reg., p ) 2015, AAMC-UHC-FPSC Page 19

20 Collaborative Care Treating patients with multiple chronic conditions can require extensive information sharing between a primary care and a specialist In CY 2014, CPT created four codes ( ) to acknowledge telephone/internet consultative services Medicare does not pay for these services arguing these consultations are already bundled in other services (already embedded in existing codes) 2015, AAMC-UHC-FPSC Page 20

21 Establishing Separate Payment for Collaborative Care Question: Should CMS bill a separate code to more accurately track consultation services between primary care (or whoever is leading the care coordination) and specialists similar to CPT ? CMS seeks data regarding the following: Beneficiary s specific conditions Parameters for providing these services and resources Differentiating these services from existing ones Beneficiary protection Necessary technology to provide these services Waivers of beneficiary financial liability in CMMI models (Fed. Reg., p ) 2015, AAMC-UHC-FPSC Page 21

22 Collaborative Care Models for Behavioral Health Conditions CMS seeks feedback regarding: Providing collaborative care for patients with common behavior conditions Including PCP, care manager, and a psychiatric consultant in the model How to code and reimburse this specific type of a model (Fed. Reg., p ) 2015, AAMC-UHC-FPSC Page 22

23 Other Items of Interest 2015, AAMC-UHC-FPSC Page 23

24 Proposed Telehealth Service Codes CMS Proposes to add 5 CPT and HCPCS Codes: prolonged service in inpatient or observation setting (1 st hr) prolonged service in inpatient or observation setting (each additional 30 minutes) ESRD related services for home dialysis (<2yrs) ESRD related services for home dialysis (2-11yrs) ESRD related services for home dialysis (12-19yrs) CMS proposes to amend to include CRNAs as practitioners for telehealth services. List of Medicare codes and descriptors available at (Fed. Reg., p ) 2015, AAMC-UHC-FPSC Page 24

25 Physician Self-Referral CMS does not propose any changes to the general exception for academic medical centers under 42 CFR (e) CMS proposes to: Update the regulations to accommodate new delivery and payment system reform models, to reduce burden, and to facilitate compliance Add two new exceptions: (1) Assistance to employ a nonphysician practitioner, and (2) Timeshare arrangements CMS seeks comments on a variety of issues, including Self-referral barriers to clinical and financial integration under reform models (such as ACOs, BPCI, APMs etc.), especially for the volume or value and other business generated criteria 80 Fed. Reg. p , AAMC-UHC-FPSC Page 25

26 Valuation of Global Services MACRA provisions re Global Services Prohibited implementation of 0-Day surgical bundles as described in PFS 2015 Final rule; CMS can review codes on case-by-case basis Authorizes Secretary to begin collecting information on surgical services no later than January 2017 Authority to withhold 5 percent of payments to physicians selected for the sample until they report the requisite data CMS seeking feedback on How to obtain auditable, objective data for post-op E/M visits Input on the accuracy of the values and description of component services within the global package Other items and services which may be provided post-op 80 Fed. Reg. p , AAMC-UHC-FPSC Page 26

27 Appropriate Use Criteria (AUC) for Advance Diagnostic Imaging Services Established by Protecting Access to Medicare Act of 2014 Criteria for physicians to better identify the appropriate imaging service; AUC will identify outlier ordering physicians for services after Jan 2017 Outlier physicians need prior authorization starting 2020 First part of implementation Defining AUC development by provider-led organizations CMS proposes requirements and process for becoming a provider-led organization 80 Fed. Reg. p Could include hospitals/health systems 2015, AAMC-UHC-FPSC Page 27

28 Questions on Payment Proposals? Please use the Q&A panel located on the right hand side of your screen to submit your questions. Send to All Panelists. 2015, AAMC-UHC-FPSC Page 28

29 Medicare Physician Fee Schedule Proposed Rule CY2016 QUALITY AND EFFICIENCY POLICIES 2015, AAMC-UHC-FPSC Page 29

30 Quality & Efficiency Policies PQRS/VM Proposals Transition to MIPS Physician Compare Feedback Reports 2015, AAMC-UHC-FPSC Page 30

31 PQRS/Value Modifier 2015, AAMC-UHC-FPSC Page 31

32 LAST YEAR for PQRS/Value Modifier Adjustments 2018 payments based on 2016 activity 2% PQRS Penalty Up to 4% for Value Modifier (for large groups) 2019 payments based on either MIPS or APM Merit-based Incentive Payment System (MIPS) Pay for performance based on quality, resource use, clinical practice improvements, and meaningful use Alternative payment models (APM) 5% lump sum bonus available EPs must meet certain thresholds; APMs must meet certain requirements NOTE: Participating in an MSSP ACO or other alternative payment model does not automatically mean the practice will be in the APM track!! 2015, AAMC-UHC-FPSC Page 32

33 Timeline of Payment Risk Potential Incentives Mcare/Mcaid EHR Varies Varies Mcaid Only Mcaid Only Medicaid Only -- Incentive a Value-Modifier +1.0(x) +2.0(x) +4.0(x) +4.0(x) (Max incentive) b MIPS TBD Bonus for Exceptional Performance Same Potential Reductions Medicare EHR Incentive % or -2.0% -3.0% Up to % c -4.0% d PQRS -1.5% -2.0% -2.0% -2.0% Value-modifier (Max -1.0% -2.0% -4.0% -4.0% reduction) b MIPS % -5.0% -7.0% -9.0% Total Possible Reduction -4.5% -6% -9% -10% -4% -5% -7% -9% a Medicare and Medicaid incentives and penalties vary by stage individual professional is at. For Medicare, eligible professionals (EPs)have to attest by 2014 to earn any incentives. For Medicaid, EPs can earn their first incentive through b Adjustment could be positive or negative. VM incentive is multiplied by an adjustment factor (x) TBD. There is an additional 1x for practices with high risk populations that receive incentives. No maximum adjustment is defined in legislation. c Penalty increases to 2% if EP is subject to 2014 erx penalty and Medicare EHR Incentive. d AFTER 2017, the penalty increases by 1 percent per year (to a max of 5%) if min 75% of EPs are not participating; otherwise max is 3% 2015, AAMC-UHC-FPSC Page 33

34 Proposed PQRS Changes Reporting requirements similar to previous years New GPRO reporting option: Qualified Clinical Data Registry (QCDR) QCDR have more flexibility in measure selection CAHPS for PQRS Optional for group registry/ehr (previously mandatory) Required for all GPRO Web (if applicable to practice) Proposed New Measures New options for cross-cutting measures 1 new GPRO Web Measure 80 Fed. Reg. p , AAMC-UHC-FPSC Page 34

35 Reporting Mechanism GPRO Web + CAHPS for PQRS Qualified Clinical Data Registry (QCDR) Registry EHR EHR/Registry + CAHPS for PQRS Group X (revised) X (new) X (revised) X (revised) X Individual X X X 2016 PQRS Reporting Mechanisms Requirements for 2015 PQRS Incentives Timing / Commitment Report all measures in the web interface for a sample of patients Group must report on at least 1 measure for which there is Medicare data (Note: practices can report GPRO Web without CAHPS if CAHPS is not appropriate) 9 measures/3 domains for 50% of applicable patients Must report at least 2 outcome measures OR at least 1 outcome measure+ 1 resource use, patient experience, efficiency/appropriate use, or patient safety measure 9 measures/3 domains (unless fewer than 9 measures apply) for 50% of Medicare Part B Pts. Report 1 cross-cutting measure if 1 face-to-face encounter Measures with 0% performance rate are not counted 9 measures/3 domains (unless fewer apply) Must use appropriate EHR specifications. At least 1 measure must include a Medicare patient; CAHPS for PQRS AND 6 measures/2 domains from EHR/Registry (see additional requirements for EHR/Registry above) Groups must use certified survey vendor. Claims X 9 measures/3 domains (unless fewer than 9 measures apply) for 50% of Medicare Part B Pts. Report 1 cross-cutting measure if 1 face-to-face encounter Measures with 0% performance rate are not counted Registry w/ Measures Groups X Report at least 1 measures group for at least 20 patients the majority of which are required to be Medicare Part B FFS patients. Measures groups containing a measure with 0% performance rate will not be counted. Annual submission Registry submits data annually. Registry submits annually. Annual submission EHR or thru EHR Data Vendor CMS to identify patients to be surveyed. Annual submission. Report concurrently with claims submission. Registry submits annually. Other Comments Available to groups with 25 or more EPs. All groups, regardless of size, must report CAHPS. New reporting option for groups 2 or more in CAHPS for PQRS no longer required for GPRO registry reporting CAHPS for PQRS no longer required for GPRO EHR reporting Available to groups with 2 or more EPs that CHOOSE CAHPS reporting. 2015, AAMC-UHC-FPSC Page 35

36 Proposed New Cross-Cutting Measures If group or individual EPs have at least one faceto-face visit, then they must report at least 1 cross-cutting measure Proposed new cross-cutting measures Preventative Care Screening: Unhealthy Alcohol Use Breast Cancer Screening Falls: Risk Assessment Falls: Plan of Care 2015, AAMC-UHC-FPSC Page 36

37 New Measure Proposed for 2016 GPRO WI 2015, AAMC-UHC-FPSC Page 37

38 Major Proposals for Value Modifier (VM) Max penalty for large group remains 4 percent Changes to VM Eligibility Certain CMMI demonstrations excluded from 2018 VM because of waiver Adjust VM eligibility to prepare for MIPS Technical calculation changes Increase number of measures for MSPB to 100 Calculate separate benchmarks electronic measures Other technical changes for apply VM to MSSP ACOs 80 Fed. Reg. p , AAMC-UHC-FPSC Page 38

39 Proposed 2018 Value Modifier 2015 PQRS Reporting Group Reporting; 50% of EPs in TIN; OR Solo practitioner NO No PQRS Reporting Automatic VM Penalty in 2018 (in addition to 2% PQRS Penalty) <10 EP TIN: -2.0% 10+ EP TIN: -4.0% Groups without physicians and include NPs, PAs, CNSs, and CRNAs: -2% YES Quality Tiering Varies based on TIN Size and Composition TINS with any professionals in selected CMMI Demos are EXCLUDED from VM including: Pioneer ACOs Comprehensive Primary Care Initiative Other identified models (could include Oncology, Next Gen ACOs, etc) MSSP ACOs are still included in the VM VM expands to certain non physicians practitioners: NPs, PAs, CNSs, and CRNAs 2015, AAMC-UHC-FPSC Page 39

40 Proposed Quality Tiering in 2018 VM Low cost Avg cost High cost Low cost Avg cost High cost TINs with 10 or more EPs Low quality Low quality Avg Quality Avg quality High quality 0.0% +2.0x* +4.0x* -2.0% +0.0% +2.0x* -4.0% -2.0% 0.0% TINs with <10 EPs High quality 0.0% +1.0x* +2.0x* -1.0% +0.0% +1.0x* -2.0% -1.0% 0.0% TINs with NP, PA, CNS, CRNA (and no physician) Low cost Avg cost High cost Low quality Avg quality High quality 0.0% +1.0x* +2.0x* 0.0% 0.0% +1.0x* 0.0% 0.0% 0.0% Most Faculty Practices will be in this Quality Tiering Grid Groups with 10 or more EPs have more at risk than smaller groups Practices with no physicians and NPs, PAs, CNSs, and CRNAs have no downside risk * Additional +1.0x if top 25% of all beneficiary risk scores 2015, AAMC-UHC-FPSC Page 40

41 Eligibility For Each Program MIPS 1 VM PQRS EHR 2 MD or DO X X X Both Dentist 3 X X X Both Doctor of Podiatry X X X Mcare Doctor of Optometry X X X Mcare Chiropractor X X X Mcare Nurse Practitioner X X 4 X Mcaid Physician Assistant X X 4 X Mcaid 5 CRNA X X 4 X Clinical Nurse Specialist X X 4 X Certified Nurse Midwife Perf Only 4 X Mcaid Others (audiologists, therapists, psychologists) Perf Only 4 1 MIPS eligibility for 2019 and May expand to other professionals in Some EPs exempt from EHR Incentives. (Example hospital based EPs are exempt from Meaningful Use.) 3 Dentists are labeled as physicians in the Medicare program but may not be affected because they do not bill PFS services 4 VM payments adjustments apply to physicians and proposed to apply to NPs, PAs, CRNAs in Other PQRS professionals are included in performance, but not in payment adjustment. 5 PAs who furnish services in a FQHC that is led by a physician assistant are included. 2015, AAMC-UHC-FPSC Page 41 X

42 2018 Value Modifier Measures Quality Measures PQRS reported measures 3 claims-based outcome measures Acute prevention quality indicators composite Chronic prevention quality indicators composite All cause readmission CAHPS for PQRS (included for MSSP, optional for other groups) Cost Measures Cost measures not condition specific Total cost per capita Medicare Spending per Beneficiary Per capita costs for 4 condition populations COPD Heart Failure Coronary Artery Disease Diabetes No New Measures for Value Modifier! Proposed changes to MSPB: Increase to Number of Admissions from 20 to 100 and include admissions from Maryland Seeking feedback on whether to stratify costs by beneficiary risk score 2015, AAMC-UHC-FPSC Page 42

43 VM and ACOs MSSP ACOs Rules to assign quality score if TIN/EPs are in more than one ACO (starting 2017 VM) CAHPS for PQRS included in the quality composite (starting 2018 VM) Pioneer ACOs and other models (starting in 2017) TIN waived if at least one EPs is in one of the identified CMMI models (Exception VM still applies if the TIN is in an MSSP ACO) 2015, AAMC-UHC-FPSC Page 43

44 Feedback on MACRA (SGR Repeal) 2015, AAMC-UHC-FPSC Page 44

45 Three Main Parts of the SGR Replacement Predictable Updates Repeals SGR Replaces with small updates through 2020 Freeze for six years Two conversion factors after 2025 Merit-Based Incentive Payment System (MIPS) Consolidates penalties from existing three Medicare reporting/ performance programs into one large pay-forperformance program Alternative Payment Models (APM) Incentives to move to Alternative Payment Models Bonus for 5 years Higher update after , AAMC-UHC-FPSC Page 45

46 Feedback on MACRA Provisions- MIPS CMS seeking feedback on MIPS definitions, particularly low-volume threshold, clinical practice improvement activities How to define low volume threshold EPs with low volume can be exempt from MIPS Min number of Medicare beneficiaries Min number of items and services Min amount of allowed charges Should CMS use thresholds like what is in MU? Possible Example: EP does not have at least 10% of their patient volume derived from Part B encounters Should it be a combination of items? 80 Fed. Reg. p , AAMC-UHC-FPSC Page 46

47 Feedback on MACRA Provisions- MIPS How to define Clinical Practice Improvement Activities Seeking feedback on activities that could be classified as practice improvement Categories mentioned in legislation: expanded practice access, population management, care coordination, beneficiary engagement, patient safety/practice assessment, participation in APM Legislation mentioned maximum credit for certified PCMH practices; at least ½ credit for APM participation 2015, AAMC-UHC-FPSC Page 47

48 Feedback on MACRA Provisions- APM Upcoming Request for Information (RFI), but CMS welcomes initial feedback Topics covered include: Criteria for assessing physician-focused payment models Criteria and process for submission of physician-focused payment models eligible APM Qualifying APM participants Medicare payment threshold option and combination all-payer and Medicare payment threshold option Time period used to calculation eligibility for APM Definition of nominal financial risk 2015, AAMC-UHC-FPSC Page 48

49 Physician Compare 2015, AAMC-UHC-FPSC Page 49

50 Key proposals: Proposed benchmarking algorithm New data on Physician Compare Website Physician Compare New indicators for VM upward adjustment, reporting on the cardiovascular prevention measures group, All PQRS measures including CAHPS and QCDRs New data in Downloadable data file Add utilization data Value modifier quality tier and payment adjustment Feedback for future rulemaking: Should CMS stratify measures by race, ethnicity, gender, other ideas? Add Medicare Advantage information? Add VM cost and quality scores? Add Open Payments data? Additional measures? 2015, AAMC-UHC-FPSC Page 50

51 Physician Compare: Benchmarking Propose using Achievable Benchmarking for Care (ABC tm ) For each measure - rank order physicians/group by highest performance Go through list until 10 percent of the beneficiaries (not providers) in denominator are selected Calculate benchmark as the score for all patients in the denominator Adjustments for low denominators Benchmark calculated every year; no discussion about different benchmarks for different data sources ABC methodology can be used to systematically assign stars for 5-star rating 2015, AAMC-UHC-FPSC Page 51

52 Questions on Q&E Proposals? Please use the Q&A panel located on the right hand side of your screen to submit your questions. Send to All Panelists. 2015, AAMC-UHC-FPSC Page 52

53 Medicare Physician Fee Schedule Proposed Rule CY2016 ALTERNATIVE PAYMENT MODELS 2015, AAMC-UHC-FPSC Page 53

54 Potential CPCI Expansion Comprehensive Primary Care Initiative (CPCI) basics CMMI model; Ends December 2016 Collaborating with commercial payers and Medicaid Practices: Receive per beneficiary per month payment for each Medicare (and sometimes Medicaid) beneficiary Has to provide comprehensive services in five different primary care areas Has to report 9 or 13 electronic quality measures at practice site level Seeking feedback on issues around potential future expansion Expansion would go through rulemaking 2015, AAMC-UHC-FPSC Page 54

55 MSSP ACO Changes Proposed change to attribution methodology Exclude nursing home visits from skilled nursing home Would affect 2017 performance year No corresponding change proposed for VM attribution One new quality measure for GPRO Web Interface 2015, AAMC-UHC-FPSC Page 55

56 Questions about PFS Proposals Mary Wheatley, Tanvi Mehta, Questions/Feedback FPSC Projects Related to PFS Dave Troland, Will Dardani, FPSC Projects Q&E Projects Shaifali Ray, Kathy Yue, , AAMC-UHC-FPSC Page 56