Urgent! Call for Comments:
CMS Changes to Fee Schedule

The Centers for Medicare & Medicaid Services (CMS) is proposing significant changes to the fee schedule that are important and dramatic for Osteopathic physicians!  

A few important points of the proposed fee schedule ( read the entire 1,472-page proposal here).

CMS proposes to pay the same fee for multiple levels of outpatient visits. Payment for new patient office visits level 2-5 (99202-99205) would be blended into a single $135 payment. Payment for an established patient office visit level 2-5 (99212-99215) would be blended into a $93 payment.

When an E/M service and procedure is reported on the same date, CMS proposes to implement a 50% multiple procedure payment reduction to the lower paid of the two services.

This is an URGENT issue for OMT providers and other physicians who perform procedures as it will cut the payment by 50%.    

Physicians will be paid for telephonic services/assessments, including preventive services, and paid for time to review video or image sent by patient seeking care or diagnosis for ailment.
CMS proposes a minimum documentation standard that requires physicians to only document information to support a level 2 E/M visit (for Medicare Physician Fee Schedule only). Physicians would not have to re-enter information into the medical record but only review and verify certain information entered by ancillary staff or beneficiaries.

The MOA is concerned that this will especially burden the chronically ill, older patients and will actively discourage doctors from caring for older and more medically complex patients.  Furthermore, this reduced documentation will make care transitions and communications between physicians more difficult.  

The CMS is collecting public comments on the proposed fee schedule until Sept. 10, 2018 and we urge our membership to comment on the proposed changes.

Please take a minute to submit your comments before the September 10th deadline.  We have only a short time to let the CMS know that these changes are not good for physicians or patients.

The information in this communication is accurate as of August 28, 2018 and is subject to change after public comments have been reviewed.

AOA Action Alert on Proposed Fee Schedule Changes

Take action on the CMS proposed E/M rule change
Physicians have until Sept. 10 to submit comments to CMS calling for the delayed finalization of payment policies for E/M visits.

CMS has proposed a rule change that will negatively affect osteopathic physicians and their patients. Let CMS know your concerns about the rule by submitting a comment today.

PUBLIC COMMENT Take action on the CMS proposed E/M rule change
Physicians have until Sept. 10 to submit comments to CMS calling for the delayed finalization of payment policies for E/M visits.

The comment period closes on Sept. 10, 2018. Follow the steps outlined below to tell CMS to stop implementation of this rule:
  1. Copy the template letter below. Be sure to edit the letter to include the city and state where you practice, as well as your name. You can add additional text if you would like to further personalize the letter. You can make these edits once you paste the letter in to the comment website.
  2. Go to the federal register's comment page for the rule, click "Submit a Formal Comment", and paste the letter template in to the text box. You can make your edits before you submit.
  3. Enter your information in the fields below the text box. Be sure you deselect "I am submitting on behalf of a third party." Click "Submit Comment" to finish the process.
Template Letter
As an osteopathic physician, I would like to thank the Centers for Medicare & Medicaid Services (CMS) for its efforts to reduce administrative regulatory burdens for physicians by proposing to simplify documentation requirements for office and other outpatient Evaluation and Management (E/M) visits for new patients (CPT codes 99202-99205) and established patients (99212-99215).

However, I am concerned that collapsing payment rates for eight E/M visits down to two rates will not achieve its goal of reducing regulatory burden.  I also disagree with the proposal to implement a multiple procedure payment reduction policy that would cut procedures by 50 percent when billed with an E/M visit appended with Modifier 25. Both of these proposals run counter to the Patients Over Paperwork Initiative, which aims to streamline regulations and reduce unnecessary burden.  If CMS' top priority is to put patients first, these policies, if finalized, may have unintended consequences that threaten Medicare beneficiaries ability to access care.  Frail and elderly beneficiaries with complex medical conditions stand to suffer the most, as they may have to seek care through multiple office visits. Ultimately, I believe these changes would decrease patient satisfaction and quality of care.

While the effort to reduce documentation and administrative burden is appreciated, I urge CMS to immediately abandon the proposed Modifier 25 reimbursement reduction policy, and delay finalizing payment rates for office and other outpatient E/M visits to allow time to work with the American Medical Association/Specialty Society RVS Update Committee (RUC) to develop appropriate rates for different level visits.

your name and title

CMS Call for Comments
MOA Offerings Fulfill LARA Requirements for Healthcare Providers

Michigan Department of Licensing and Regulatory Affairs (LARA)
(Note: Pain management rules regarding CME on page 8)

Pain & Symptom Management 
Minimum 3 hours per 3-year period (effective December 2017) 
LARA R 338.143 
Applies to all osteopathic physicians, including residents, whether or not they are in active practice (ex. retired, administrative, academic teaching, etc.)

Training on Identifying Human Trafficking Victims  
Training on Identifying Human Trafficking Victims 
(one-time requirement)  LARA R 338.120
MOA Webpage:  www.domoa.org/stophumantrafficking
Michigan Osteopathic License Requirements
For your Michigan license requirements, visit the  Michigan Board of Osteopathic Medicine and Surgery (PDF) or contact them directly at 517-335-0918

Autumn Convention LARA sessions:

Friday, Nov. 16, 11 am - 12 pm Human Trafficking Training  

Andrea Rocafort, MSN, RN, CPEN, TCRN, Helen DeVos Children's Hospital Supervisor 

Meahgan Pear, Chair, Kent County Human Trafficking Task Force


Sunday, Nov. 18, 7:30 - 10:30 am Pain & Symptom Management
David Best, DO, MS, ABAM; Pam Lynch, Social Worker;
William Morrone, DO, MS, FACOFP; Panel Discussion

Beaumont Proton Therapy

Safer radiation therapy with fewer side effects
Beaumont Proton Therapy Center Tour
Beaumont Proton Therapy Center Tour

Beaumont's Proton Therapy Center is one of the most innovative and comprehensive image-guidance systems for proton beam therapy available today, offering patients a safer cancer treatment option with fewer side effects.

Proton therapy is a high-tech alternative to conventional radiation therapy (X-ray radiation), offering greater precision to destroy cancerous cells and spare adjacent healthy tissue with fewer side effects. Beaumont is the first, and only, Proton Therapy Center in Michigan.


Origami Brain Injury Rehabilitation Center to Offer Comprehensive Driver Rehabilitation Service

Receives Grant From the Michigan Health Endowment Fund

Origami Brain Injury Rehabilitation Center has received a grant from the Michigan Health Endowment Fund (MHEF) to support the expansion of their Return to Driving service.
Origami's driver rehabilitation service features a state-of-the-art driving simulator, global electric motor vehicle on campus trails, and behind the wheel evaluations. Origami has brought the entire driver rehabilitation process under one roof, helping to streamline learning or re-learning to drive.
Origami will now serve drivers of all ages with neurologic and developmental disabilities through their driver rehabilitation service, which now includes behind the wheel evaluations and a retraining program.
"Our goal in providing individuals with behind the wheel evaluations and training is to create a safer roadway for all while promoting the highest level of independence for the individual," said Tammy Hannah, President & CEO of Origami as she reflected on their motivation to expand their driving service.
Hannah continued stating, "The MHEF grant allows us to meet the growing demand of our community and create a comprehensive driving service for individuals in need of on the road training."
As a part of Origami's driver rehabilitation service, occupational therapists provide comprehensive clinical assessments and vehicle modification/conformance assessments, driver readiness and rehabilitation evaluations, and senior driving evaluations. In addition, Origami provides driver cessation and alternative transportation counseling.
Origami has purchased a new vehicle for behind the wheel evaluations that is specially equipped with instructor brake and controls, hand controls, specialty knobs, adapted mirrors, and assistive steering.
In addition to assisting individuals recovering from an injury to be able to drive again, these services are being offered to teens with disabilities that may need additional support in their driver education and training. "We know there are teens who are eager to pass their driving test, and parents who are uncertain if this will be possible. Our expertise and compassion makes our driver training the perfect opportunity for these potential drivers," said Amanda Carr, Director of Rehabilitation.
Origami Brain Injury Rehabilitation Center is a non-profit organization located in Lansing, Michigan. Origami provides the region's broadest spectrum of neuro-rehabilitation services for survivors of brain injuries and their families. Origami partnerships include the Michigan State University College of Osteopathic Medicine Department of Physical Medicine & Rehab and Peckham Industries.


Opportunity for exemption from MIPS reporting

Opportunity for exemption from MIPS reporting CMS experiments to see if removing quality reporting requirements could drive better value health care.

The Centers for Medicare and Medicaid Services (CMS) recently announced a new demonstration project that offers physicians who participate in Medicare Advantage an opportunity to opt out of the Merit Based Incentive Payment System (MIPS).

The new Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) demonstration project is designed to test whether exempting certain MIPS-eligible clinicians from reporting requirements can lower costs and improve care. It will be available to physicians who participate in certain payment arrangements with Medicare Advantage Organizations (MAOs).

The demonstration is designed to measure whether the MIPS exemption can:
  • Increase participation in payment arrangements with MAOs that meet criteria for Qualifying Payment Arrangements
  • Incentivize providers to transform their care delivery
  • Change utilization patterns among participants in the demonstration

Criteria for participating in the demonstration include:
  • Physicians must meet the combined thresholds for sufficient participation in Qualifying Payment Arrangements with MAOs and Advanced APMs
  • Submit the required documentation demonstrating compliance with Qualifying Payment Arrangement Criteria, which are the same as Advanced Alternative Payment Model (AAPM) criteria under the Quality Payment Program (QPP).
Physicians who are interested in participating can apply on the demonstration's webpage.

Applications will be accepted until September 6, 2018.

Free Access to Coverys Education - Powered by Med-IQ ®
Coverys provides all MOA members with free access to award-winning clinical and risk management education. Coverys Education is powered by Med-IQ's suite of accredited activities which includes dozens of educational topics and a range of web-based learning platforms.
Receive CME Credits 
MOA members can earn AOA CME by taking Med-IQ online courses approved by ACCME for AMA PRA Category 1 online CME.  
AOA Category 2-A credits awarded for live interactive CME activities.  
AOA Category 1-B credits awarded for on-demand internet activities.

Med-IQ Library of CME courses

 Upcoming Events

MOA Membership Committee Meeting
Date: Thursday, September 13, 2018
Time: 6pm
Location: MOA offices and via Zoom
Origami Brain Injury Rehabilitation Center
Outdoor Concert and Celebration
Date: Tuesday, September 18
Time: 5:30 - 7:30 pm
Location: 3181 Sandhill Rd, Mason, MI 48854

Council of Interns and Residents Meeting
Date: Wednesday, September 19th
Time: 7:00pm
Location: MOA offices and via Zoom

Ingham Osteopathic Association (IOA) Meeting
Date: Wednesday, October 10, 2018
Time: 6pm
Location: The University Club

Autumn Scientific Convention: November 16-18, 2018 | Grand Rapids, MI
Location: Amway Grand Plaza
More information and registration available at: www.domoa.org/gr2018

120th Annual Spring Scientific Convention: May 16-19, 2019 | Southfield, MI
Location: Westin Southfield Detroit
More information will be available January 2019

June 29, 2018 saw the passing of H. John Barkay, DO 
June 9, 2018 saw the passing of Richard W. Adams, DO
May 31, 2018 saw the passing of Steven Pitt, DO
April 22, 2018 saw the passing of Henry Gonte, DO
Click here for a local obituary  
April 9, 2018, saw the passing of Paul Thomas, DO
March 15, 2018, saw the passing of Alice Kathleen Shanaver, DO
Join us on social media:
The MOA Pulse connects our DO family with our partners, followers and the healthcare communities of Michigan. If you have any news or events you would like to us share, or if you have any questions or concerns, please feel free to contact:
Todd Ross
Manager of Communications
Michigan Osteopathic Association
Michigan Osteopathic Association | 800.657.1556 | www.domoa.org