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Tuesday Feb 06, 2018

Part I: Sharing Our Legislative, Regulatory Priorities for 2018

"Fly like an eagle."
– Steve Miller Band

Congratulations to the Philadelphia Eagles on their Super Bowl victory. Now that Super Bowl LII is over, that can only mean one thing for sports fans -- spring training. Yes, that's right. One week from today, pitchers and catchers report, marking the beginning of the 2018 Major League Baseball season. Opening Day is March 29, and, for the first time since 1968, every team will play on Opening Day 2018. My beloved Washington Nationals open in Cincinnati and will host the New York Mets in their home opener on April 5.

[priorities list with red marker]

The Second Session of the 115th Congress is well underway, and last week President Trump delivered his first State of the Union (SOTU) address(www.c-span.org) to a Joint Session of Congress. The SOTU is the traditional opportunity for presidents to frame their domestic and foreign policy priorities for the year. President Trump touched on a couple of health care issues in his address -- opioid epidemic, prescription drug prices and the repeal of the individual mandate -- but his speech largely focused on economics, national security and foreign affairs.

This post seems like a good time for me to outline some of the AAFP's legislative and regulatory priorities for the year. Due to limited word count, I will do this in two posts. These posts will provide an overview of our top-tier priorities, and by no means will they be an exhaustive list of all the issues and topics we will be working on in 2018. Additionally, this does not account for new issues that might emerge during the course of the year. As you know, the legislative and regulatory process always produce a few surprises.

Finally, these are not necessarily in a prioritized order. I have aligned the issues with the AAFP's strategic objectives under six topics: payment reform; practice transformation; workforce; clinical expertise; health care coverage and financing; and advocacy operations. This week, I will discuss payment reform and practice transformation.

Payment Reform

  • Advanced Primary Care Alternative Payment Model(38 page PDF) (APC-APM) -- On Dec. 19, 2017, the Physician-Focused Payment Models Technical Advisory Committee (PTAC) approved the AAFP's APC-APM proposal for testing. https://www.aafp.org/media-center/releases-statements/all/2017/aafp-applauds-green-light-for-alternative-payment-model.html The next step is to work with HHS, CMS and the Center for Medicare and Medicaid Innovation (CMMI) to further refine the model and recruit physicians to participate in the testing phase.

    The AAFP is extremely excited about the opportunities the APC-APM presents to fundamentally change the primary care payment model and provide family physicians a more equitable and predictable revenue stream that is unencumbered by excessive administrative requirements. Lots more to come on this issue, so stay tuned.

  • MACRA implementation -- First, a gentle reminder that you have until March 31 to report data for the 2017 performance period(qpp.cms.gov).  That is just over 50 days remaining. The 2018 performance period is underway, and eligible physicians are required to participate in one of the two payment pathways (MIPS or Advanced APM). The AAFP continues to advocate for improvements to the program. Our top priority is ensuring the availability of a greater number of Advanced APMs for family physicians. Implementation of the APC-APM is a central part of this strategy.

    Our second priority is to dramatically simplify the MIPS program, starting with a reduction in the quality reporting requirements and simplification of the EHR usability requirements under the advancing care information (ACI) component.

    Our third priority is to continue the low-volume threshold exemption for small practices but create a voluntary opt-in option for these practices. Many practices that are currently exempted have expressed a desire to participate in the program and we are exploring ways to make that possible on a voluntary basis. If you are participating in the MIPS program, I encourage you to consult the AAFP's 2018 MIPS Playbook,  an excellent step-by-step guide on how you can be successful in MIPS. This is one of many resources you will find on our MACRAReady pages.

  • Medicaid to Medicare parity -- The Affordable Care Act required that state Medicaid programs compensate qualifying primary care physicians at Medicare rates for a defined set of primary care services (primarily E&M and prevention codes). This program was extremely popular and beneficial to family physicians participating in the Medicaid program, but it has expired. A handful of states have continued the program independent of federal support, but it is our goal to once again extend the program to all states.

Practice Transformation

  • Administrative and regulatory reform -- The issue(s) of reducing the administrative and regulatory burden on family physicians is a major priority for the AAFP, and we are pursuing this objective with public and private payers. I wrote about this issue a couple of times during the past year -- here and here.

    In January 2017, the AAFP issued an Agenda for Regulatory and Administrative Reforms.  In December of 2017, the AAFP Board of Directors approved the Academy's Principles for Administrative Simplification(4 page PDF), which serve as the foundation of our advocacy efforts on these issues.

    We also have been working closely with CMS Administrator Seema Verma and her team on the Patients Over Paperwork initiative. On Oct. 26, 2017, AAFP President Michael Munger, M.D., joined Verma at the launch of the initiative in Washington, DC. You can read Munger's comments here(280 KB PDF).

    Finally, we have been working closely with America's Health Insurance Plans (AHIP) and the large commercial insurers to identify ways to reduce the administrative burden on family physicians. Our top targets are the development of a uniform prior authorization form for all insurers, the elimination of PAs for generic medications, and the elimination of PAs for diabetic supplies. There is a substantial amount of work to do in this area, but we are devoting substantial attention to reducing burden for you and your practices.

  • Direct Primary Care -- DPC continues to grow as an alternative to the traditional insurance-based practice model for family physicians. We continue to be excited about the model and its potential. Our advocacy efforts are three-fold. First, we are committed to providing tools, resources, and education to DPC practices. The AAFP's DPC Toolkit is a great resource for those who are in the early stages of starting a DPC practice. In addition, we offer some of the best DPC education programs in the nation. I encourage you to join us at the 2018 DPC Summit(www.dpcsummit.org) or FMX 2018, where you will find a full menu of education offerings on DPC ranging from "let's get started" to "working with employers." Finally, we have a lively and informative DPC Member Interest Group. This resource is a great place to meet other DPC physicians and to engage in discussion on items impacting DPC practices.

    Our second advocacy objective is to improve the regulatory framework to better align DPC practices with patients. A key to achieving this objective is the enactment of the AAFP-supported Primary Care Enhancement Act(www.congress.gov). This legislation would clarify that individuals are allowed to use their HSA accounts to facilitate a relationship with a DPC practice by determining that the monthly membership fee for a DPC practice is an allowable medical expense. The AAFP has worked closely with the bill's sponsors for several years and is committed to seeing this legislation enacted into law during the 115th Congress.

    Finally, the AAFP has been working closely with the Trump Administration, especially Verma, on expanding opportunities for the DPC model in Medicare, Medicaid and the health insurance marketplaces. Many of these efforts are active, but I am confident that we may see some significant activity on these efforts later this year. Stay tuned.

I hope you have found this information informative. Again, this is not an exhaustive list so if you do not see an issue, it does not mean we are not working on it. In two weeks, I will outline our work on workforce; clinical expertise; health care coverage and financing; and advocacy operations.  

Posted at 09:00AM Feb 06, 2018 by Shawn Martin

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Shawn Martin, AAFP Senior Vice President of Advocacy, Practice Advancement and Policy.

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