Official NTOCC Comments

Review the official comments, letters and responses from the National Transitions of Care Coalition (NTOCC).

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Posted on 7/25/2018 by NTOCC ®


                   IMPACT NEWSLETTER                     
  July 2018 

"Tackling the Opioid Abuse Issues and Building Support through Voices for Non-Opioid Choices
On July 25th health care professionals and consumers from across the country attended a Washington DC fly-in to address the issues of Opioid misuse and abuse and to discuss the need for access to non-opioid approaches to pain management with members of Congress.  Dr. Jim Lett, President of NTOCC was able to meet with Senator Benjamin L. Cardin of Maryland and his staff to talk about the issues and shared the concerns of Geriatric providers when addressing pain management for seniors and the opioid impact on safe transitions and hospital admissions/readmissions. 
The fly-in group met with Congressmen/Congresswomen and staff from the House and Senate to share personal stories of the national tragedy of opioid addiction, and programs they are heading that are currently available to address the need for preventive and recovery treatment, including access to non-opioid therapies."

Quality Payment Program Update

Written by Christopher J. Laney, JD, CHCQM

Member, ABQAURP Board of Directors


The Medicare Access and CHIP Reauthorization Act (MACRA) became law on April 16, 2015. Among other things, MACRA repealed the Sustainable Growth Rate Formula (SGR) that had been in place since the Balanced Budget Act of 1997. The SGR was an attempt to slow the rate of growth in Medicare Part B expenditures by limiting year-over-year growth in physician payment rates, and had been overridden by Congress’s “doc fix” legislation every year from 2002 through 2014. MACRA implemented that Quality Payment Program (QPP), which replaced the SGR and several other programs, including Meaningful Use, the Value Based Modifier, and the Physician Quality Reporting System. The QPP became Medicare’s new physician payment methodology, emphasizing quality and efficiency.

Providers can choose to participate in one of two QPP tracks, the Merit-based Incentive Payment System (MIPS), or the Advanced Alternative Payment Model (Advanced APM). Participation in MIPS, the default position, subjects providers to a Medicare Part B fee schedule adjustment beginning at plus or minus 4% in 2019 and rising to plus or minus 9% in 2022, based on providers’ performance on a number of measures, including quality and cost. Providers can qualify for the Advanced APM track by participating in alternative payment models that generally require providers to assume some downside risk for the cost of care. These providers do not participate in MIPS and receive an automatic 5% payment bonus.

The Centers for Medicare & Medicaid Services (CMS) is responsible for implementation of the QPP and published the final rule for the 2018 QPP performance year on November 16, 2017. While CMS did not make any fundamental changes for the second year of provider participation, it did continue implementation of the QPP, especially on the MIPS track, and provided several favorable changes for solo providers and small practices.

Continuing with its “ramp up” of MIPS in year two (2018) toward “full implementation” in year three (2019), CMS finalized rules to introduce the Cost category for performance year 2018. In 2017’s first year of participation, providers were not scored on cost or efficiency of care—in 2018 it will count toward 10% of a provider’s final performance score. For the 2019 performance year, CMS has flexibility to either keep the Cost category at 10% of the final score, or to expand it to up to 30% of the final score. In keeping with its initial plans to gradually increase the stakes of the MIPS program, provider Part B payments will be subject to an adjustment of plus or minus 5% based on 2018 performance—up from 4% in the initial 2017 performance year. These payment adjustments will take place two years after the performance year, to allow time for CMS to validate performance and payment results.

The biggest changes for the 2018 performance year pertain to impact on small practices. Smaller providers have consistently maintained that the QPP, and the MIPS program in particular, favor large practices with the resources and infrastructure to effectively manage to the CMS programs. In the 2018 final rule, CMS has attempted to address the concerns of small practices with several changes to the MIPS program.

The first change is to increase the threshold for “small practice exclusion” from MIPS. Practices with 15 or fewer providers with $90,000 or less in Part B allowed charges or 200 or fewer Part B beneficiaries will be excluded from MIPS. CMS estimates that 586,000 providers will qualify for this exclusion in 2018, up from 384,000 in 2017. The second change is to give those small practices that are not excluded from participation in MIPS five bonus points out of a possible 100. The third change is that otherwise unaffiliated solo and small groups of providers up to 10 members will be eligible to report MIPS data to CMS using a “virtual group.” CMS hopes that this allows smaller practices without access to the infrastructure and resources of larger groups to more effectively take advantage of pooled resources and expertise across providers.

While the CMS 2018 QPP final rule did not make any fundamental changes to the QPP, it did introduce some small changes and kept the ball rolling toward full implementation of the program in 2019. The 2018 final rule will make it easier for smaller groups to avoid participating, but for those providers who do participate, there will be more stringent requirements, and the stakes will be higher.


Christopher J. Laney, JD, CHCQM

Mr. Laney earned a Bachelor of Arts from Michigan State University, is a cum laude graduate of Wayne State University Law School in Detroit where he served on the Law Review, and holds a Graduate Certificate in the Foundations of Public Health from the University of Michigan’s School of Public Health. Mr. Laney serves on the ABQAURP board of directors as well as the CME and Exam Committees.


NTOCC Policy & Advocacy Corner

Dear NTOCC Community,
Please take a moment to read through the legislation that we post in this section each Quarter. The bills are being monitored by NTOCC in regards to Transitions of Care community.  You can click on the bill numbers for more information, and please do not hesitate to reach out to your members of Congress and express your opinion in regards to these issues. 

If you have any bills that you would like for us to consider adding to our list please send them to me at 

Kindest Regards, 
Val Emmons
NTOCC, Director of Communications & Public Policy

Bills we are currently monitoring:

S. 2911 To require the Secretary of Health and Human Services to provide guidance to States regarding Medicaid items and services for non-opioid pain treatment and management. IN THE SENATE OF THE UNITED STATES MAY 22, 2018 Mr. HELLER (for himself, Mr. CASEY, Mr. THUNE, Ms. STABENOW, Mr. CORNYN, and Mr. NELSON) introduced the following bill; which was read twice and referred to the Committee on Finance A BILL To require the Secretary of Health and Human Services to provide guidance to States regarding Medicaid items and services for non-opioid pain treatment and management. 1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 3 SECTION 1. SHORT TITLE. 4 This Act may be cited as the ‘‘Enhancing Patient Ac5 cess to Non-Opioid Treatment Options’’.


Introduced on May 22, 2018 by Senator Dean Heller (R) a Senior Senator for Nevada. 

In committee; Read twice and referred to the Committee on Finance on 18-05-21. (This bill is in the first stage of the legislative process. It was introduced into Congress on May 22, 2018. It will typically be considered by committee next before it is possibly sent on to the House or Senate as a whole.)

H.R. 6   AN ACT To provide for opioid use disorder prevention, recovery, and treatment, and for other purposes.  SECTION 1. SHORT TITLE—This Act may be cited as the  ‘‘Substance Use-Disorder Prevention that Promotes  Opioid Recovery and Treatment for Patients and Communities Act’’ or the ‘‘SUPPORT for Patients and Communities Act’’.

Introduced on June 13, 2018 by Congressman Greg Walden (R) Representative for Oregon's 2nd congressional district. 
Parts Incorporated Into Other Measures 
:This bill passed in the House on June 22, 2018 and goes to the Senate next for consideration. Provisions of this bill were incorporated into other bills.
Provisions of this bill also appear in: S. 1091: Supporting Grandparents Raising Grandchildren Act
Enacted — Signed by the President on Jul 7, 2018.  

H.R. 6343  
INPATIENT Act of 2018 

To provide for a demonstration program and pilot project to expand choice for inpatient psychiatric services under Medicaid and Medicare.

Introduced  on July 12, 2018 by Congressman Bill Huizenga (R) Representative for Michigan's 2nd congressional district. 

This bill is in the first stage of the legislative process. It was introduced into Congress on July 12, 2018. It will typically be considered by committee next before it is possibly sent on to the House or Senate as a whole.

H.R. 184 Protect Medical Innovation Act of 2018
To amend the Internal Revenue Code of 1986 to repeal the excise tax on medical devices. (Effective in 2013, the Affordable Care Act imposed a 2.3% excise tax on the manufacturer’s price of certain medical devices intended for consumption in the United States.) 


Introduced on January, 03, 2017 by Congressman Erik Paulsen (R) Representative for Minnesota's 3rd congressional district. 

This bill passed in the House on July 24, 2018 and goes to the Senate next for consideration.


S. 2278: State Offices of Rural Health Re-authorization Act of 2018 
UPDATE: Passed Senate on Jul 24, 2018 and goes to the House next for consideration.

A bill to amend the Public Health Service Act to provide grants to improve health care in rural areas. (The federal budget process occurs in two stages: appropriations, which set overall spending limits by agency or program, and authorizations, which direct how federal funds should (or should not) be used. Appropriation and authorization provisions are typically made for single fiscal years. A reauthorization bill like this one renews the authorizations of an expiring law.)
Status: The committees assigned to this bill sent it to the House or Senate as a whole for consideration on February 28, 2018. 

S. 292: Childhood Cancer STAR Act
UPDATE: Enacted — Signed by the President on Jun 5, 2018

A bill to maximize discovery, and accelerate development and availability, of promising childhood cancer treatments, and for other purposes.
Status: This bill passed in the Senate on March 22, 2018 and goes to the House next for consideration.


The Executive Director's Corner
News and updates from the NTOCC Executive Director’s desk.


Dear NTOCC Community,

NTOCC had a successful Conference Day in Washington DC on May 24th, Celebrating Transitions of Care Excellence”.  We send a thank you to the many speakers and attendees who made this event a success.  Programs of excellence in Transitions of Care is one of the goals NTOCC supports in bringing awareness, education and resources to professionals, consumers, legislators and the media.  I would like to encourage any of you within the NTOCC community who have developed and implemented transitions of care programs, to share those successes by sending us your 500-750-word article on the program.  We would love to feature your program in our upcoming quarterly IMPACT.

We have been working to address the gaps and barriers related to poor transition for over 12years and hope that you as a follower of NTOCC will take the time to share the resources with other colleagues available on the website and the upcoming “Lunch & Learn Series” continuing in September.  Also feel free to forward the IMPACT to any one in your community.

NTOCC is working with two health systems conducting a quality improvement study assessing the improvement to transitions of care for heart failure patients and their caregivers from the hospital to home and/or outpatient care.  This study will involve the use of NTOCC’s TOC Evaluation Software adapted with specific tools/interventions for improving transitions for heart failure patients. Our plan is to share the results of the study towards the end of the year and to make available the enhanced TOC Evaluation Software to the NTOCC community and healthcare industry.  Please stay tuned for those events.

Last year NTOCC in partnership with PRIME Education, LLC developed “An Interdisciplinary Guide for Safer Care Transitions and Fewer Readmissions for Heart Failure” through an educational grant from Norvartis Pharmaceutical.  This pathway can be found on the NTOCC website home page in the Knowledge and Resource Center. If you have not reviewed the white paper, please do and take advantage of earning continuing education credits provided by PRIME Education, LLC.

As many of us are aware there is a tremendous effort on addressing the issues of Opioid Misuse and Abuse developing at both the federal and state levels.  Once again this brings into focus how well are patients and family caregivers informed about choices and shared decision making including safety and quality of care in regards to these medications?  Do we address these concerns at various transitions of care? NTOCC is working to assess and support improved education and greater understanding and choice of non-opioid alternatives. Our goal will be to bring additional tools and resources to the community in the third quarter of this year.


Cheri Signature.jpg                                                                                                                                                                  
Cheri Lattimer

Executive Director