lobbying_activities: 1985026
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| id | filing_uuid | filing_type | registrant_name | registrant_id | client_name | filing_year | filing_period | issue_code | specific_issues | government_entities | income_amount | expense_amount | is_no_activity | is_termination | received_date |
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| 1985026 | 5e231365-9255-4d8c-aafb-be5807644fd2 | Q2 | MARSHFIELD CLINIC HEALTH SYSTEM | 57830 | MARSHFIELD CLINIC HEALTH SYSTEM | 2017 | second_quarter | MMM | Many aspects of the Affordable Care Act promote changes that are consistent with the mission of the Marshfield Clinic: Extends health insurance to the uninsured Calls for Value Based Purchasing for all providers Calls for the establishment of Accountable Care Organizations The following are key elements of the health policy agenda of the Marshfield Clinic Health System: Medicare Access and CHIP Reauthorization Act With passage of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), Congress has put to rest the constant threat of massive cuts to Medicare physician fees. Going forward Medicare physician payments will transition to an incentive-based system based on value and accountability. Starting in 2019, Medicare physician payment will be based on the Merit-Based Incentive Payment System (MIPS). Physicians who perform well on quality, value and IT metrics will be rewarded with higher pay rates and those who perform poorly will face penalties. Participants in Alternative Payment Systems (APMs) such as accountable care organizations that assume financial risk will receive 5% bonuses between 2019 and 2024. Because the language of the statute is not specific, the Centers for Medicare and Medicaid Services (CMS) is developing metrics that will be used to determine the bonus payments and penalties that will start in 2019 in a public rulemaking currently underway. The proposed metrics simplify and consolidate the existing measurements employed under the Meaningful Use Incentive Program, the Physician Reporting System (PQRS), and the Value-Based Modifier (VBM) to streamline the reporting burden for physician practices. MIPS will then pay physicians based on four weighted performance categories: Quality (50% of total score in year 1), Advancing Care Information (25% of total score in year 1); Clinical Practice Improvement Activities (15% of total score in year 1): Resource Use (10% of total score in year 1, but growing to 30% in subsequent years). Having a source of credible data as the foundation of CMS metrics is critical both to fair payment and maintaining access to medical services in rural areas. CMS will be refining the metrics perpetually throughout the lifespan of this program. Challenges to fair reimbursement persist under the current Medicare fee schedule, which remains the foundation of the reimbursement system, particularly in regard to the valuation of primary care and the geographic adjustment of physician wages. These challenges must be addressed. Adequate funding for CMS to implement and maintain this new system is critical to patient care, provider education and acceptance of the new program and its long term success. Congress must ensure that CMS has adequate funding to provide oversight of its many programs, including its measurement of resource and input costs and full implementation of the Affordable Care Act and MACRA. MCHS also supported MACRA provisions that extended funding for the Childrens Health Insurance Program and provided $7.2 billion to community health centers over the next 2 years, postponed cuts in payments to hospitals that treat large numbers of low-income patients; and extended provisions that funded geographic adjustment of the physician work, therapy services and payments for rural hospitals. Medicare Advantage The Medicare Advantage program provides a full-risk, capitated reimbursement to health plans for all Medicare benefits provided to enrolled beneficiaries. We believe that mechanisms for rewarding value in the Medicare Advantage program should offer incentives for those plans that demonstrate superior patient care performance. We recommend that performance bonuses should be provided for plans that: Achieve predetermined quality performance targets; Adopt health information technology; Meet standards for care coordination; and Provide data on comparative effectiveness. The Medicare Advantage Benchmark Cap - ACA SEC. 3201. (b) (4) By authorizing Quality Incentive Payments for MA plans with star ratings of 4 stars and above, Congress made a significant policy change towards value-based purchasing in the MA program. If a plan is eligible for a Quality Incentive Payment, it receives it in the form of a 5 percent increase to its benchmark. However, Congress also authorized a new methodology for calculating benchmarks, and mandated that benchmarks under the new methodology cannot be greater than what they would have been under the old benchmark methodology. This is the benchmark cap. The benchmark cap reduces or even eliminates Quality Incentive Payments. The policy issue is that the cap weakens the incentive for plans to attain higher star ratings and undermines the shift towards paying for performance in the MA program. We do not think that Congress intended to take away with one provision (the cap) the significant policy change towards paying for value that it enacted in the ACA. This change will have a significant negative impact on Medicare Advantage beneficiaries. CMS has indicated that it wants to remove the cap administratively, and we believe that HHS and CMS have the discretionary authority under law to make the necessary changes. If HHS and CMS do not make the change, then a statutory change will be necessary in the 115th Congress. The benchmark cap costs Medicare Advantage enrollees in Security Health Plans population more than $25 more in their monthly premium. Graduate Medical Education MCHS is concerned about having a sufficient supply of primary care physicians to meet the demands of an expanding and aging population. This is doubly true for patients and health systems in rural settings. Currently only about 10% of physicians practice in rural areas while 25% of the population resides there. While 36% allopathic residents and 50% osteopathic residents who are trained in a rural residency end up practicing in a rural area, only 4% of the residency training actually occurs in rural areas. Currently there are more US medical students graduating from medical school than there are GME slots. An increase in GME primary care training positions is essential to maintaining high-quality, accessible, and cost efficient care. Teaching hospitals in rural locations provide an environment for residents to learn and faculty to serve as educators, providers and researchers. These roles advance the broad mission of preparing each generation of physicians, provide critical patient care and specialized services, often to the disadvantaged, facilitate the discovery of new therapies and treatments, and enable residents to acclimate to the rural setting. As new payment and delivery models emphasize primary care to improve patient outcomes and reduce costs, and as more care shifts to outpatient settings, teaching faculty and residency programs must increase access to ambulatory residency rotations to serve Americans who live in areas with an under-supply of primary care physicians including Geriatrics and Psychiatry. The purpose and value of residency training in clinical settings and the financial support needed to sustain physician education will only increase as the U.S. population lives longer with more complex health conditions. To ensure GME can meet the future needs of the newly insured and aging population, Congress must commit to the consistent GME funding and lift Medicares limit on funded residency positions. We support the Teaching Health Center funding in the Medicare Access and CHIP Reauthorization ACT (MACRA) for Community Health Centers but request you extend funding beyond 2017. Geographic Adjustment of Physician Payments Recent findings by the Institute of Medicine (IOM) and the Medicare Payment Advisory Commission have demonstrated significant shortcomings in the data utilized to geographically adjust physician payments. The IOM and MedPAC studies have confirmed that the data sources currently relied upon for geographic adjustment bear no correlation to physician earnings. CMS officials have admitted that the proxies utilized for the purpose of geographic adjustment have never been validated, and there never has been a new data source utilized in the twenty years since the fee schedule was implemented. MedPAC data show that the geographic adjustment reference occupations predict earnings of rural physicians to be 25-30% less than physicians in metropolitan areas. MedPAC data show that earnings of primary care physicians in rural areas are, in fact, 13% higher than physicians in metropolitan areas. Since there is no statistical basis of support for disparities in payment we strongly recommend that Congress require CMS to correct this inequity immediately. These corrections are necessary to assure the credibility of the changes enacted in MACRA. Telemedicine in Medicare Changes to Medicare law and regulation are needed to improve equity in access for Medicare beneficiaries to services delivered via TeleHealth. Medicare beneficiaries should be allowed to receive services in telemedicine sites located in urban areas. The necessary changes would remove restrictions on originating sites by removing the rural requirement and the list of originating sites and allowing any certified Medicare facility to provide the services; current requirements that physician must bill for services from the originating site should be removed; restrictions on eligible practitioners should be removed to allow all Medicare approved practitioners to provide telemedicine services; and there should be no restrictions on which Medicare services may be provided through telemedicine. We recommend that the Medicare requirement for non-MSA geographic location of the patient be expanded to allow all Medicare certified organizations as originating sites regardless of rural or metropolitan statistical area designation. In addition, MCHS supports the CONNECT for Health Act that contains a provision which would permit Medicare Advantage plans to use telehealth or remote patient monitoring technologies to provide basic Medicare benefits, without the restrictions that limit originating sites, geographic locations, store-and-forward technologies, and types of health care provider. We believe that telehealth is a different way of delivering an already covered service, and that Medicare should treat remote access technologies as an alternative modality or complementary means of providing clinical services, and not a service itself. In other words, telehealth should not be seen as simply a supplement or complement to face-to-face encounters. Patients increasingly expect their health plans to provide the access to services and convenience that remote technologies facilitate. These technologies can increase communication between providers and patients, enhance care coordination, and help physicians and patients work together to treat illness and maintaining health. Oral Health Coverage for the Medically Compromised and at Risk Populations There is sufficient data that demonstrates oral health impacts the systemic health of the patient and in doing can reduce the cost of care. Linkages that encourage patient compliance, patient education, provider education, and bi-directional referral and surveillance should be incented and compensated. Shared savings demonstrations should be developed for health systems and co-pay incentives developed for patients engaging in and complying with such inter-disciplinary care. Protecting Access to Medicare Act of 2014 (PAMA) PAMA includes reforms to the Clinical Lab Fee Schedule (CLFS). This rule for PAMA requires reporting of Clinical lab prices and volumes. MCHS requested a delay in the reporting, and changes to expand the definition of applicable lab to represent the true market of all laboratories; requested greater transparency of calculations; more time to allow for gathering data and implementation. Flexibility in coverage of care that saves long term costs: Marshfield Clinic Health System has been a leader in providing care in alternative settings that saves cost, maintains quality and improves patient experience. Programs such as our comfort and recovery suites cut approximately a third of the costs vs hospitalization. Marshfield Clinic Health System would advocate for the opportunity to use these programs for any patient, but due to regulatory barriers cannot (e.g. Medicaid beneficiaries). | Centers For Medicare and Medicaid Services (CMS),Health & Human Services, Dept of (HHS),HOUSE OF REPRESENTATIVES,SENATE,Veterans Affairs, Dept of (VA) | 90000 | 0 | 0 | 2017-07-11T13:31:19.420000-04:00 |