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Have You Been Asking Yourself These Same Practice Questions?
The practice @ aan.com email inbox is an efficient way to reach Academy staff and member experts with your practice-related questions about payer relations, MIPS/MACRA, coding, and practice management. Staff experts respond within one business day and, if needed, can seek real-world guidance of the Practice Support Network, a group of 30 practicing neurologists and graduates of the AAN’s Practice Leadership Program, or the Business Support Network, a group of six business administrators in various practice settings. Below are some common questions that have come into the inbox recently.
Payer Relations
Q: How can our small practice use comparative data with local neurologists to assist with payer negotiations?
A: On June 14, 2023, the AAN’s Care Delivery and Coding and Payment Policy Subcommittees hosted an “Ask Me Anything” webinar about payer relations. The panelists provided various recommendations for negotiating with payers, including the importance of telling the story behind your practice’s data. For example, a practice with radiology (MRI) is more likely to demonstrate a higher use of diagnostic services, but this ultimately may be more efficient than sending the patient to the hospital for the same service. Adding context to your patient population and practice pattern data can help payers become more receptive to your individual reimbursement proposal. Additionally, the AAN’s annual Neurology Compensation and Productivity Survey can serve as a valuable benchmarking tool. Payers are often influenced by quality data, and whether you participate in MIPS or use the Axon Registry ®, you should be able to articulate how your practice may offer a shorter wait time, higher patient satisfaction, or promote administrative savings. For more information, recordings of the AAN’s Practice Management Webinars can be found at AAN.com/education/practice-education-webinars
Quality Payment Program
Q: My neurology group applied to waive MIPS reporting due to COVID-19 in 2020. Are MIPS reporting flexibilities still available after the end of the public health emergency?
A: The Centers for Medicare & Medicaid Services (CMS) will continue to offer relief related to COVID-19 to Merit-based
Incentive Payment System (MIPS)-eligible clinicians, groups, and APM entities. CMS has indicated that the Extreme and Uncontrollable Circumstances Exception will be available for the 2023 MIPS performance year, as it has been since 2020. This means that MIPS-eligible clinicians and groups may submit an application requesting reweighting of one or more MIPS performance categories. The 2023 application is available at qpp.cms.gov/mips/exception-applications. You can learn more about MIPS and the Quality Payment Program at AAN.com/QPP
Payment Policy
Q:If I use modifier 95 to indicate a service was furnished via telehealth, do I also need to include a place of service code?
A: In the 2023 Medicare Physician Fee Schedule Final Rule, CMS clarified that practitioners should continue to bill using modifier 95 in addition to the place of service (POS) code that corresponds to where the service would have been furnished in person. The POS code “10” indicates that the patient received telehealth services in their home, whereby “home” indicates a location other than a hospital or other facility. POS code “02” should be appended to claims for telehealth furnished in locations other than a patient’s home. Through the remainder of 2023, CMS will reimburse practitioners for telehealth at the same rate as if the service were furnished in person. This includes maintaining the payment parity that was initiated during the public health emergency for telehealth provided in non-facility settings. For more information about telehealth, visit AAN.com/telehealth
MIPS Reporting: Comparing Axon Registry Scores to All Neurology
The desired outcome of Merit-based Incentive Payment System (MIPS) reporting is for a clinician or group to receive a positive payment adjustment applied to the clinician’s or group’s Medicare reimbursements. So, how do MIPS scores reported from the Axon Registry ® compare to MIPS scores reported for neurology as a whole?
Much better, as it turns out.
To make this comparison, we used the most current MIPS scores available, which are from 2020 from the Centers for Medicare & Medicaid Services (CMS). AAN staff compared the 2020 MIPS final scores from the Axon Registry against the 2020 MIPS final scores of all neurology individual and group submissions. For 2020, there were 90 individual and group MIPS submissions through the Axon Registry compared to about 7,600 neurology individual and group MIPS submissions to CMS.
Comparisons
For individual 2020 MIPS reporting, the average MIPS final score for Axon Registry submissions was more than 10-percent higher than the average MIPS final score for all neurology submissions.
Average 2020 MIPS final score via Axon Registry— 70.65 points
Average 2020 MIPS final score for All Neurology— 63.47 points
For individual 2020 MIPS submissions, 87 percent of Axon Registry submissions received a positive payment adjustment (or with an exceptional performance bonus) for 2022 Medicare payments. On the other hand, among all neurology 2020 MIPS scores only 46 percent of individuals reporting received a positive adjustment (or with an exceptional performance bonus). Only in the Positive Adjustment Plus Exceptional Performance Bonus segment did the All Neurology contingent outperform the Axon Registry contingent.
Furthermore, 53 percent of all neurology individual 2020 MIPS submissions received a neutral payment impact for 2022 Medicare payments, compared to zero percent of the registry participants.
No group MIPS score analyses were performed as the CMS MIPS score data didn’t provide details for the composition of each group. Group MIPS reporting is done at the tax identification number (TIN) level, meaning a group MIPS score analysis would compare multispecialty groups to neurology groups.
A great benefit of Axon Registry participation is the opportunity to perform MIPS reporting using neurology-specific quality measures. Neurology clinicians may have a positive impact on neurology-specific quality measure performance within their practice. To learn more about the Axon Registry or to enroll, visit AAN.com/axon or contact registry @ aan.com
Vascular Neurologist—Ascension Saint Agnes—Saint Agnes Hospital—Baltimore, MD, United States
Seeking Fellowship trained Vascular neurologist to direct our dual certified Primary Stroke Program by The Joint Commission (TJC) and Maryland Institute for Emergency Medical Services System (MIEMSS). Working with 4 other multi sub-specialty trained neurologists for inpatient consultations and outpatient clinical activities. Program includes our well-established cerebrovascular service with gold and elite plus status. The program infrastructure includes our dedicated Nurse Practitioner and Stroke coordinators. Current director planning retirement. For more information reach out to Kelly Morin, Director, Operations at Ascension at kmorin@ascension.org
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