GREAT NEWS! ASIPP SCORES A MAJOR VICTORY AND CONCESSIONS FOR MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS) WITH 90-DAY REPORTING
The Medicare Access and CHIP Reauthorization Act (MACRA) /Merit-based Incentive Payment System (MIPS) final rule
has been released unexpectedly this morning.
Now we can call it meaningful changes instead of meaningless use.
The Centers for Medicare and Medicaid
Services (CMS) has made substantial changes. We are extremely pleased
that they have accepted at least part of our recommendation in reference
to a 90-day period reporting rather than full year.
However, the 90-day period was ASIPP's idea. It really helped us to go to Washington and advocate for our positions.
Here is the summary of MIPS as we read it. We are very optimistic, but again, we are cautiously optimistic.
More good news is in the works for interventional pain physicians on MIPS registries, etc. We will keep you posted.
CMS will create a 90-day reporting
period for clinicians reporting in MIPS, the final rule states. The
agency is reducing the number of measures to be reported from 11 to
five. Providers will have the option of reporting all the dropped
Reporting to public health or clinical
data registries will result in a bonus. CMS is also exploring whether to
count managing referrals and consults as part of the MIPS reporting.
The final rule also outlines CMS's
"pick-your-pace" route to MIPS reporting. Given the wide diversity of
clinical practices, the initial development period of the Quality
Payment Program implementation would allow physicians to pick their pace
of participation for the first performance period that begins January
(1) Clinicians can choose to report to
MIPS for a full 90-day period or, ideally, the full year, and maximize
the MIPS eligible clinician's chances to qualify for a positive
adjustment. In addition, MIPS eligible clinicians who are exceptional
performers in MIPS, as shown by the practice information that they
submit, are eligible for an additional positive adjustment for each year
of the first 6 years of the program.
(2) Clinicians can choose to report to
MIPS for a period of time less than the full year performance period
2017 but for a full 90-day period at a minimum and report more than one
quality measure, more than one improvement activity, or more than the
required measures in the advancing care information performance category
in order to avoid a negative MIPS payment adjustment and to possibly
receive a positive MIPS payment adjustment.
(3) Clinicians can choose to report one
measure in the quality performance category; one activity in the
improvement activities performance category; or report the required
measures of the advancing care information performance category and
avoid a negative MIPS payment adjustment. Alternatively, if MIPS
eligible clinicians choose to not report even one measure or activity,
they will receive the full negative 4 percent adjustment.
(4) MIPS eligible clinicians can participate in Advanced Alternative Payment Models ( APMs), and if they receive a sufficient
portion of their Medicare payments or see a sufficient portion of their
Medicare patients through the Advanced APM, they will qualify for a 5
percent bonus incentive payment in 2019.
(5) Other provisions:
- Financial and technical assistance (100 million) to small and rural practices
- Teases that more advanced APMs will be available by January 2017
- Finalizes most of the APM portions of the proposed rule
- New estimate is 200 million distributed under MIPS, down from 833 million
ASIPP Has Great Legislative Session in Washington, DC
Approximately 50 members of ASIPP attended a great
legislative session in Washington, DC. Members and staff had great visits with many
senators and members of the House, including multiple committee chairs.
It appears that we are making substantial progress in making changes
for MIPS. Following is the proposed language for MIPS. We also have
other language for Medicare Advantage Plans. MIPS language is as
- Delay the implementation of merit-based incentive payment
system (MIPS) by one-year, to January 1, 2018, reporting year,
retaining 2019 as penalty/bonus year (performance year), and change
participation of MIPS for 3 months per year, with 2017 serving as a
training year to meet criteria for meaningful use, physician quality
reporting system, and value-based payment.
CMS and Medicare to provide appropriate local coverage determinations
(LCDs), based on the integrity manual, utilizing proper evidence.
- LCDs must be issued in addition to validated
wide-spread problem identified for potentially high dollar or high
volume services and requested by providers for coverage issues to be
added, to assure beneficiary access to care, or when frequent denials
are issued or anticipated.
- LCDs must be prepared with input from specific
specialty Carrier Advisory Committee (CAC) membership and other CAC
- Noncoverage policies must be only issued by CMS with
appropriate review process and evidence synthesis with public comment
for procedures usually performed with available evidence.
- Medicare Advantage Plans must offer a "benefit
package" that is at least equal to Medicare's and coverage everything
Medicare covers, with or without LCDs.
At the same time ASIPP was in the halls of the Congress, CMS
announced that they will be providing multiple options for
implementation of MIPS including an option of delay; however, this does
not include all our issues. Consequently, we continue to fight on this
Here are links to the statement from CMS and the Congressional letter:
Another Big Development:
CMS has issued its revised decision on coverage of Percutaneous Image-guided Lumbar Decompression (PILD) procedure
which does not remove all the restrictions; however, it expands the
coverage. They are asking to perform another cohort CMS approved study.
This is some progress, success, and good news, but not the greatest
news in the world. Obviously the struggle continues for coverage of
(left) Dr. Manchikanti presents the Lifetime
Achievement Award to Ed Whitfield in his last hours of congressional
membership in a heartfelt and almost tearful setting. (right) ASIPP hosted a fundraiser for New Jersey Chairman Rodney Frelinghuysen.
ASIPP Announces Patient Education Program
The American Society of Interventional Pain Physicians (ASIPP), a not-for-profit national organization representing interventional pain physicians, and Medical Media, Inc., dedicated to medical marketing, announced today they have entered into a collaborati on agreement to form Interventional Pain Management Network, a new patient education program. Dr. Laxmaiah Manchikanti, ASIPP Chairman of the Board, said,
“Interventional Pain Management Network consists of interactive videos for waiting rooms as an innovative way to provide awareness and understanding of evidence-based and clinically relevant information to the
patient at a time when the patient is in need and receptive to health issues.
Read complete media release >>>
A Seamless Navigation to ICD-10-CM for Interventional Pain Physicians: Is a Rude Awakening Avoidable?
Since October 1, 2015, the International Classification of
Diseases, 10th Revision, Clinical Modification (ICD-10-CM) was
integrated into U.S. medical practices. This monumental transition
seemingly occurred rather unceremoniously, despite significant
opposition and reservations having been expressed by the provider
community. In prior publications, we have described various survival
strategies for interventional pain physicians.
The regulators and beneficiaries of system - CMS, consultants, and
health information technology industry are congratulating themselves for
a job well done. Nonetheless, this transition comes at an immeasurable
financial and psychological drain on providers. However, a rude
awakening may be making its way with expiration of initial concessions
from government and private payers.
This manuscript provides a template for interventional pain
management professionals with multiple steps for seamless navigation,
including descriptions of the most commonly used codes, navigation
through ICD-10-CM manual, steps for correct coding, and finally,
detailed coding descriptions for various interventional techniques.
Group Purchasing Organization – Join
ASIPP has formed a partnership with Henry Schein and PedsPal, a
national GPO that has a successful history of negotiating better prices on
medical supplies and creating value added services for the independent
physician. Working with MedAssets, PedsPal provides excellent pricing on
products like contrast media that alleviate some of the financial pressures you
experience today. While the cost of contrast media has skyrocketed due to the
single dose vial issue, because we have partnered with Henry Schein, this could
enable you to purchase Omnipaque 240mg/50 ml for slightly above
It will be easy for ASIPP members in good standing to enroll today and begin to realize the
savings this partnership can bring. Members can join or see sample prices by
going to http://pedspal.org/asipp/default.html
Click on “view our discounted supplier prices” ( Username:ASIPPmember and Password: Save
) or click on the words "join for free now" and begin saving today!
Update on PQRS Implementation
Among multiple regulations, we are also faced with documentation for
the physician quality reporting system. Now the bonuses have ended and penalties
are being imposed on non-participation starting last year. If you did not
complete them for 2014, you will see a 2% reduction in Medicare fee-for-service
amounts for services furnished during 2016. The same is true for 2015; if you
did not complete documentation for 2015, you will face a penalty in 2017 and
2016 will result in a penalty in 2018. After 2018, the PQRS payment adjustment
will be transitioned to a merit-based incentive payment system, or MIPS, as
required by the Medicare Access and CHIP Reauthorization Act (MACRA) of
We have attempted to make it palatable for interventional pain
physicians to meet the criteria. Recently, we published a manuscript on
Physician Quality Reporting System (PQRS) for Interventional Pain Management
Practices: Challenges and Opportunities (click here for manuscript).
Essentially, PQRS is one of the easiest to implement among all the
regulations. Enclosed, please find the recommended measures for IPM providers.
There are 9 measures included and 3 optional measures. The included measures are
utilized by the undersigned (click here for table in Word).
Final Voyage of FDA and MPW Epidural Saga: Victory for Practicing Interventional Pain Physicians
The FDA has now determined that they will not amend the drug safety communication; however, they will not adopt the 17 recommendations made by the MPW (See Letter). This ruling by the FDA is a major victory for practicing interventional pain physicians that avoids micromanagement (FDA citizen’s petition) and the additional bureaucracy created by the MPW. The FDA also published an article in the New England Journal of Medicine which essentially alludes to the same facts as described, and in no uncertain terms, they emphasize the fact that they are not withdrawing the issued warning, but they also were not endorsing the standards from MPW, even though they facilitated the discussion.
Consequently, the epidural saga continues even though this may be the final chapter.
Who is your IPM CAC Representative?
In March 2005, the Centers for Medicare and Medicaid mandated that Interventional Pain Management become the 34th medical specialty represented on state Carrier Advisory Committees (CAC), which make local decisions about Medicare coverage. It spite of the great efforts it took to secure this position, many states are still without representation.
It is critical that IPM have representation in every state. Do you know who your representative is? More Information on CACs.
Change Your Specialty Designation
Use the CMS Form to Change your Specialty Designation to 09 - Interventional Pain Management
We are faced with the need to increase our 09 Interventional Pain Management specialty designation. Currently CMS claims there are too few IPM physicians, which negatively affects our reimbursement. Interventional Pain Physicians can now change their specialty code designation to 09 utilizing the CMS form CMS855I - see page 8, section D.
Find Your Elected Officials
Stay on top of the issues affecting interventional pain management, know your elected and appointed officials and contact the media in your area. You can make a difference by getting involved! Find out who represents you on Capitol Hill, go to Capwiz: http://www.asipp.org/Alert.htm
ASIPP Launches ASIPP®/PainPhysician Job Board
The ASIPP/Pain Physician Job Board is where talented and qualified interventional pain management physicians connect with great organizations and some of the best jobs available.
Candidates can browse current vacancies, post an anonymous resume and create new job alerts. Employers can post a job or browse the resume bank to find the right candidate.
Click here to access the Job Board...
Order Your ICD-10-CM Pocket Book
ICD-10-CM has been one of the most onerous issues for interventional pain management in recent years; however, now it is here and we do not have any other choice other than to follow. There are multiple reports already with substantial denials despite so-called protection from Centers for Medicare and Medicaid Services (CMS). We have written multiple manuscripts on ICD-10-CM and also tireless worked for seamless navigation. To make life easy and promote seamless navigation, we have developed a comprehensive, practical, pocket guide for ICD-10-CM coding for interventional pain physicians.
To make life easy and promote seamless navigation with ICD-10-CM, ASIPP® has developed a comprehensive, practical, pocket guide for ICD-10-CM coding for interventional pain physicians. Designed for interventional pain physicians and their staff, this pocket guide goes beyond basic ICD-10-CM coding and helps to promote seamless navigation through 2016 and beyond.
This book clearly provides direction for clinical coding with assessment and provides guidance on specific coding for each procedure showing the intricacies and steps to avoid rejections.
The book is a 5"x8" size which can be placed in your jacket or any carrying case. The price is highly reasonable. You can recover the cost of the book by avoiding mistakes in one single case. Order with bundled print and electronic versions at $400, or individual print or electronic versions at $250.
Click here to order >>>
Order these IPM Board Review materials which are designed to prepare
physicians seeking board certificatin, re-certification, or an in-depth
review of the specialty of interventional pain medicine.
SELECT FROM BOOKS, EBOOKS, DVD VIDEOS, OR ONLINE VIDEOS
Comprehensive and Timely Books
This three-volume set from ASIPP Publishing was created to give clinicians a complete study course to prepare for pain medicine board certification exams, based upon the curriculum of the American Board of Medical Specialties pain medicine examinations. These books take clinicians on a journey through the specialty of pain medicine and interventional pain management, from their origins and history, to the science and research behind methods and techniques, to pharmacology, types of pain, complementary therapies, and interventional and surgical techniques, and much, much more. Culminating with a comprehensive resource of 1,500 sample board exam questions, complete with thorough explanations of the answers, these books will not only help prepare clinicians for their board examination, they will become valuable resources that will be consulted for years to come.
Click here to order books >>>
Comprehensive and Convenient eBooks
The three-volume set from ASIPP Publishing created to give clinicians a complete study course to prepare for pain medicine board certification exams, based upon the curriculum of the American Board of Medical Specialties pain medicine examinations is now available in ebooks. Now you will be able to download the ebook version of these books to hand held devices for easy accessiblity for the mobile world we work in. These books take clinicians on a journey through the specialty of pain medicine and interventional pain management, from their origins and history, to the science and research behind methods and techniques, to pharmacology, types of pain, complementary therapies, and interventional and surgical techniques, and much, much more. Culminating with a comprehensive resource of 1,500 sample board exam questions, complete with thorough explanations of the answers, these books will not only help prepare clinicians for their board examination, they will become valuable resources that will be consulted for years to come.
Click here to order ebooks >>>
Videos on DVD
the Videos and receive 5 days of course video on a set of five DVDs.
You can watch them on your computer, save them to your computer, or
transport them with you to view somewhere else. And you will be able to
load this on your iPad for viewing or just to listen to when you're
Click here to order DVD videos >>>
the online videos and receive 5 days of course video via the Internet.
You can watch them on your computer or any computer with Internet
access. You will be given a password to access the high quality
streaming video of each day.
Click here for sample of video >>> http://vimeo.com/28213117
Click here to order online videos >>>
IPM Practice Guidelines
"The guidelines are expected to increase patient compliance, dispel miscommunications among providers and patients, manage patient expectations reasonably, and form the basis of a therapeutic partnership between the patient, the provider and payers, " said Laxmaiah Manchikanti, MD, ASIPP, CEO and Chairman of the Board.
Click on the headline for our articles on evidence-based practice guidelines for interventional techniques in the management of chronic pain. Or go to National Guidelines Clearinghouse for ASIPP's 2009 Interventional Techniques: Evidence-based Practice Guidelines in the Management of Chronic Spinal Pain.
Guidelines By Year: 2009 | 2007 | 2006 | 2005 | 2003 | 2001 | 2000
Order Interventional Techniques Brochures for your Practice.
ASIPP Marketing Services has produced a series of informative and illustrative brochures and are making them
available to you.
View the brochures before ordering.
brochures include descriptions of pain conditions
and procedures, along with accompanying illustrations. The
brochures are designed specifically for the
interventional pain physician. They can be used to communicate with
patients and referral sources in personal settings or via direct mail.
The brochures are supplied in a pdf format. All you
have to do is have your printer place your logo and practice information
in the designated area. It is a quick and easy way to have the
brochures you need in develop patient and referral relations.
Click here for more information and ordering >>>
l Over 90,000 words l Over 2400 references l 50 Tables l 20 Figures l 300 Formatted Pages