Tag Archives: Centers for Medicare & Medicaid Services

CMS Finalizes CY2018 OPPS & PFS Rules

By Blair Burnett, ACCC Policy Analyst

Bipartisan healthcare talks may have stalled in Congress as tax reform takes center stage, but the Centers for Medicare & Medicaid Services (CMS) finalized the CY 2018 Hospital Outpatient Prospective Payment Systems (OPPS) and Physician Fee Schedule (PFS) rules last week, bringing big changes to Medicare reimbursement in 2018. For highlights, read on.

2018 OUTPATIENT PROSPECTIVE PAYMENT SYSTEM HIGHLIGHTS
Overall, in 2018, CMS will increase OPPS payment rates by 1.35 percent.

340B – Most notably, the 2018 OPPS rule finalized substantial cuts to Part B drug reimbursement for 340B hospitals. Starting January 1, 2018, 340B entities will be paid Average Sales Price (ASP) minus 22.5 percent, instead of ASP plus 6 percent, for separately payable drugs that were acquired under the 340B Program, excluding drugs on pass-through status and vaccines. Most 340B entities are included in this reduction; however, for 2018 there are exemptions for rural sole community hospitals (SCHs), PPS-exempt cancer hospitals, and children’s hospitals. In the final rule, the agency reserves the right to revisit these exemptions in 2019. Drugs not purchased under the 340B Drug Pricing Program will continue to be paid at ASP plus 6 percent.

Early estimates suggest that this cut will produce $1.6 billion in savings which will be redistributed through a 3.2 percent increase in payment for non-drug items and services across all hospitals.

Operationally, CMS will also require the use of a modifier to identify whether a drug was purchased under the 340B Drug Pricing Program. One modifier will be required for hospitals that are subject to the payment reduction and another modifier for hospitals who are exempt from the payment reduction but still acquire drugs under the 340B Program.

ACCC and many other stakeholder groups advocated strongly against this proposal and hoped for a more constructive policy conversation about real reforms to the 340B program. Several hospital groups, including the American Hospital Association (AHA), the Association of American Medical Colleges (AAMC), and America’s Essential Hospitals, are considering a lawsuit to stop CMS from finalizing these reductions.

Drug Packaging – Under the prospective payment system, CMS has continually put forward policies that move OPPS toward bundled payments. In 2015, CMS conditionally packaged payment for ancillary services assigned to an APC group with a geographic mean cost of $100 or less, but excluded low-cost drug administration services. In 2018, CMS is finalizing its policy to conditionally package payment for low-cost drug administration services.

In 2018, CMS also extends non-enforcement of direct supervision requirements for outpatient therapeutic services for Critical Access Hospitals (CAHs) and rural hospitals with 100 or fewer beds in 2018 and 2019. Additionally, the agency is making changes to the date-of-service policy (i.e., the “14-day rule”) so that, in general, labs can bill Medicare directly for advanced diagnostic laboratory tests (ADLTs) and molecular pathology tests.

2018 MEDICARE PHYSICIAN FEE SCHEDULE HIGHLIGHTS
Overall, in 2018, CMS will increase physician payment rates by 0.41% with no combined impact on hematology/oncology and an estimated 1% increase for radiation oncology and radiation therapy centers.

Payment Rates for Non-excepted Off-campus Provider-Based Hospital Departments – CMS is finalizing a reduction to payment rates for services provided at non-excepted off-campus hospital outpatient provider-based departments (i.e., off-campus facilities that began billing under OPPS after Nov. 2, 2015). Payment rates for services provided at these facilities will change from 50 percent of the OPPS rate to 40 percent of the OPPS rate. The agency states that this payment decrease is meant to “level the playing field” between hospitals and physician practices by promoting “greater payment alignment.”

Biosimilars – In a reversal of agency policy, CMS also finalizes a policy that each biosimilar product will receive its own unique reimbursement code. This is a departure from a policy in the CY 2017 OPPS Final Rule requiring that biosimilar products that rely on a common reference product be grouped into the same payment calculation for determining a single ASP payment limit.

Telehealth Services Expansion – In the 2018 PFS, CMS significantly expands telehealth services, adding numerous codes to the telehealth services list – including new codes for visits to determine low dose computed tomography eligibility, interactive complexity, health-risk assessments, care planning for chronic care management, and psychotherapy for crisis. To reduce the administrative burden for providers, CMS is also finalizes a proposal that will not require reporting a telehealth modifier on future telehealth claims.

Additionally, CMS finalizes that practitioners will be required to begin reporting consultation of appropriate use criteria (AUCs) beginning in 2020.

ACCC members are invited to join us for a webinar on Wednesday, November 29, 2017 from 3-4 PM EST, for an in-depth analysis of how these final 2018 payment rules may impact your cancer program or practice. Learn more and register.

CMS Part B Drug Demo Unlikely to Move Ahead

By Leah Ralph, Director of Health Policy, ACCC

Centers_for_Medicare_and_Medicaid_Services_logoJust before Thanksgiving, top Senate Democrats asked the White House not to issue a final rule on the Center for Medicare and Medicaid Innovation (CMMI) proposed Part B Drug Payment Model – a national program that would significantly reduce reimbursement for Part B drugs. This was  a good sign for our efforts against the proposal, and on November 21, we passed an important deadline for CMMI to release a final rule. We are now within a 60-day window of the new Administration taking office, which, if a final rule were to be released, due to a series of administrative rules in Congress, makes it much easier for the new Administration to simply pull back the rule rather than having to do it legislatively.

Simply put: we passed a critical deadline, and we’re very optimistic that we will not see a final rule on the Medicare Part B Drug demonstration for the remainder of the current Administration. ACCC spoke out strongly against this ill-conceived proposal. Hundreds of ACCC members weighed in with their members of Congress, and ACCC produced financial analysis that we shared with the committees of jurisdiction in both the Senate and House of Representatives that showed precisely how devastating cuts to Part B drug reimbursement under this proposed model would be on both practices and hospitals. ACCC thanks you for your efforts to block this poorly-conceived experiment. This is a victory for cancer patients and providers across the country who can now continue to provide high-quality cancer care close to home.

With a new year and a new Administration upon us, we will continue to face both opportunities and challenges in the oncology policy landscape. ACCC is committed to preserving the cancer delivery infrastructure, and we will continue to work with policymakers to develop thoughtful policies around value-based care and an appropriate, sustainable reimbursement system for all settings of care.

With Final MACRA Rule, CMS Increases Flexibility

By Leah Ralph, Director of Health Policy, ACCC

Healthcare costsOn Friday, October 14, the Centers for Medicare & Medicaid Services (CMS) released its final rule on the MACRA Quality Payment Program (QPP).  ACCC is conducting an in-depth analysis of the rule; however, an initial look reveals that CMS has heard the stakeholders’ message  loud and clear: Make the transition to MACRA as simple and flexible as possible. Here are some top-level highlights from the final rule:

  • Low-volume threshold exemption: the agency broadened the low-volume threshold exemption from the Merit-Based Incentive Payment System (MIPS), exempting practices with less than $30,000 in Medicare charges or fewer than 100 unique Medicare patients per year. This will exclude about one-third of physicians from having to report under the Quality Payment Program (QPP).
  • Pick your pace: CMS is allowing physicians to “pick their pace” in 2017, enabling physicians to avoid negative penalties in 2019 by reporting on some data (i.e., one quality measure) for some period of time. The takeaway: even minimal performance reporting will exempt physicians from any penalties, and opportunities for a shorter, 90-day reporting period will make providers eligible for positive adjustments. (Providers must start collecting data between January 1, 2017, and October  2, 2017, and report no later than March 31, 2018.)
  • Resource use category weighted zero in first year: MIPS has four components, and originally the resource use (cost) category was going to account for 10% of your score starting in 2017. CMS has now said this category will hold zero percent weight toward your MIPS score in the first year [in 2017, the percentages will be: 60% quality measures, 25% advancing care information (EHR use), and 15% clinical improvement activities].
  • Expanding opportunities to participate in APMs: CMS has also said it plans to expand opportunities to participate in models that qualify as “advanced alternative payment models” (APMs) in 2017 and 2018. The Center for Medicare and Medicaid Innovation (CMMI) also informed Oncology Care Model (OCM) practices on Friday, October 14, that CMS is amending the program to allow OCM practices to take two-sided risk as early as January 2017 to qualify as an advanced APM (two years earlier than the model originally allowed).

In our comments on the proposed rule, ACCC asked for increased flexibility for practices who are still building the infrastructure to meet these requirements, and a streamlining of reporting requirements as our members increasingly engage in new delivery models and navigate the path to value-based care. ACCC’s major concerns were around timeline and administrative burden – in the final rule, CMS was responsive in many ways, but ACCC will continue to work with the agency to reduce regulatory burden and make this a workable payment system for our members.

For more information, CMS launched a website for physicians that explains the program and allows you to explore and identify different measures that are most meaningful to your practice. Find a summary of the rule here. The AMA and ASCO also have great checklists on how to prepare for participation in the QPP.

 

CMS Eases MACRA Quality Payment Program Timeline

By Leah Ralph, Director of Health Policy, ACCC

Centers_for_Medicare_and_Medicaid_Services_logoIn response to considerable pressure from industry stakeholders, medical groups and policymakers, the Centers for Medicare & Medicaid Services (CMS) announced last week that it would provide increased flexibility for practices to report out and comply with new data and performance requirements under the Quality Payment Program (QPP), created by the Medicare Access and CHIP Reauthorization Act (MACRA) passed last year.

In a blog post titled “Plans for the Quality Payment Program in 2017: Pick Your Pace,” Acting CMS Administrator Andy Slavitt lays out four pathways to compliance with the new Quality Payment Program (in order of easiest to the hardest):

  • Report some data.  Providers can avoid a negative penalty by submitting some data as required by the Quality Payment Program, including data from after January 1, 2017. CMS states this option is “designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019.” This option allows you to avoid a negative payment adjustment in 2019.
  • Participate for only part of the calendar year. Providers may submit data as required by the Quality Payment Program for a reduced number of days (not the whole year), and the performance period could begin after January 2017. Under this option, you could still qualify for a small positive payment adjustment in 2019.
  • If you’re ready to go in 2017, participate for the full calendar year. For practices that are ready to go and choose this option, their performance period will begin January 1, 2017, and they will submit data under the Quality Payment Program for a full year. These practices will qualify for a modest positive payment adjustment in 2019. CMS expects many practices will be able to do this.
  • Participate through an Advanced Alternative Payment Model (APM).** While the three previous options would fall under the Merit-Based Incentive Payment System (MIPS) track, the fourth option allows providers who are receiving a certain percentage of Medicare payments or seeing a certain number of Medicare patients through a qualifying APM (the provider is taking two-sided or “more than nominal” risk) to participate through the Advanced APM track. These providers would qualify for a 5% incentive payment in 2019 in addition to any savings produced through the APM and would not be subject to MIPS requirements. (**Remember CMS lays out a very high bar to qualify for the APM track in the proposed rule: 90% of physicians are expected to choose MIPS).

Until 2019, physicians will see an annual 0.5% increase in payments, at which point payments will then be determined by performance in the Quality Payment Program either through MIPS or an advanced APM.

CMS has said the decision to provide leniency was in recognition of the “wide diversity of physician practices.” The agency has also said it is considering alternative start dates, shorter performance periods, increased flexibility for small or rural practices, and finding other ways for physicians to get more experience with the program requirements before being penalized.

CMS originally proposed that providers begin to report on measures outlined under the Quality Payment Program in January 2017 but that payments would not reflect that performance period until 2019. However with the new guidance from CMS, the easiest option essentially does not require real provider participation in 2017, but allows providers to test whether their systems are ready to fully participate in the future. While the details of the measures will remain unclear until a final rule is released, the Quality Payment Program will require practices to submit information on quality measures, how they use technology, and what improvement activities they are undertaking.

Through our comments to the agency in  June, ACCC advocated for increased flexibility and more time for physicians to prepare for undertaking the new requirements under the Quality Payment Program. We also asked the agency to restructure the APM requirements so that they are more achievable.

We commend CMS for releasing flexibility prior to a final rule on MACRA, which we expect to see later this fall, and ask for continued accommodations for practices that face myriad new requirements in the coming months and years.

ACCC Annual Meeting: Five Key Takeaways

by Amanda Patton, ACCC Communications

ACCC 42nd Annual MeetingNearly 500 oncology professionals gathered in Washington, D.C., last week for the 42nd ACCC Annual Meeting, CANCERSCAPE. Throughout sessions centered on policy, value, and quality, attendees heard a recurrent message: Your experience, perspective, and input on the issues of value-based care, quality measures, and outcomes are essential as the healthcare system and oncology transition to the new world of alternative payment models and value-based care.

From ACCC Capitol Hill Day last Wednesday throughout the meeting sessions, attendees were urged to educate policymakers and payers about the real-world processes involved in delivering quality cancer care.

In the meeting’s opening session, Congressman Rick Nolan (MN-D)  called out the vital role ACCC members can play in helping educate legislators and policymakers, “No one can articulate need, challenges, potential to ultimately cure cancer [better] than the people in this room today,” he said.

Can precision medicine be reconciled with value-based care? “Absolutely” said Kavita Patel, MD, MS, of the Brookings Institution.  Oncology already delivers personalized (or precision) medicine through targeted therapies for some cancers, she pointed out. Communicating about the oncology care process so that policymakers understand real-world cancer care delivery is imperative, Patel said. Part of that conversation should aim to help policymakers understand the demanding intuitive thought process that is part of today’s oncology care, along with the tremendous amount of information cancer care providers must keep up with given the pace and variety of emerging therapies. “It’s not writing prescriptions,” she said.

Five Key CANCERSCAPE Takeaways

High-level meeting takeaways that interconnect value, policy, and quality include:

  1. Alignment. For value and quality measures to work in oncology, alignment among payers, providers, and patients is essential.
  2. Put your data to work. Cancer programs and practices are finding ways to harness their data to improve quality patient-centered care and reduce costs. In a presentation on Collaboration Across Specialties to Improve Care and Curb Costs, Matthew Manning, MD,  from Cone Health demonstrated how his program used data to identify “hotspotters,” assess gaps in care, improve outcomes, and reduce costs.
  3. Communicate. Support conversations across silos and among stakeholders. Engage with patients to understand their goals of care and to define value and quality. While value frameworks are generic, “all patients are different” agreed panelists in a Town Hall discussion on Value Framework Tools.
  4. Be proactive. Don’t wait until USP Chapter 800 goes into effect to assess your facilities readiness. Don’t wait until HRSA issues its final 340B mega-regulation. Take steps today to assess your program’s compliance. “Be prepared” was also the message in a Biosimilars Update from Nisha Pherwani, PharmD, BCOP, clinical director of Oncology, Cardinal Health. She urged attendees to:
    • Understand the FDA approval process for biosimilars
    • Provide a concise review to your P&T committee
    • Review the FDA guidances on biosimilars
    • Stay tuned for more on how interchangeability will impact regulations.
  5. Speak up. Oncology providers can best articulate the care they provide and the issues impacting care delivery. Leadership in oncology has to step forward to help define quality and value and inform policy. Work with ACCC to make your voice heard.

This week’s CMS release of a proposed rule designed to test new Medicare Part B drug payment models makes clear the critical need for the oncology community stay on top of what is happening among policymakers in Washington, D.C.  ACCC has voiced strong opposition to CMS’s proposal. Among other concerns, ACCC points to the lack of opportunity for stakeholder input on the development of this proposal.

ACCC urges its members speak up and ask Congress to stop the CMS Medicare Part B Drug Payment Model.  Click here to contact your legislators.

Annual Meeting Highlight: Medicare Update & What to Expect in 2016

By Amanda Patton, ACCC Communications

ACCC 42nd Annual Meeting-ConwayAt the ACCC 42nd Annual Meeting last week, Lindsay Conway of The Advisory Board Company updated attendees on Medicare payments and what to expect in 2016.  Not surprisingly, her presentation touched on issues related to the meeting’s central themes of policy, quality, and value.

Two examples of the forward momentum in quality this year will be “testing” new oncology quality measures through PCHQR Quality Reporting Measures and CAHPS for Cancer Care.  Field testing for the CAHPS for Cancer Care is wrapping up, Conway said, and we can expect to see the CAHPS trademark on three oncology-specific surveys this summer.  Specifically, we will see a survey for surgical oncology, a survey for radiation oncology, and a medical oncology survey. Each survey will consist of about 85 questions and will likely reflect five CAPHS domains, including:

  1. Effective Communication
  2. Shared Decision Making
  3. Enabling Patient Self-Management
  4. Technical Communication
  5. Access

Looking ahead, Conway noted that new policies are supporting population health goals while also slowly moving forward with payment for value. As examples, she cited recent Medicare policies related to biosimilars, advance care planning, and lung cancer screening.

As cancer programs plan strategically for the future, Conway suggests keeping an eye on the following:

  • Payment equalization—which is gaining momentum
  • Progression of site-neutral payment policies
  • Physician practice acquisition—the equation is becoming increasingly complex from both the hospital and the physician practice perspectives
  • Alternative payment models (APMs), in particular the Center for Medicare and Medicaid Innovation (CMMI) Oncology Care Model.

The CMS OCM initiative, which will pilot a value-based reimbursement model in oncology, is on everyone’s radar screen, as the oncology community awaits the agency’s announcement of practices selected for participation. Conway acknowledged that the OCM model is complex and that many questions remain about how CMMI will implement the model.

The ultimate benefit for those participating in the OCM will not be financial, according to Conway. The benefits for participants will be strategic, e.g., new data sets, benchmarks, more data about the patients being served, the opportunity to develop competencies in operating in a risk-based environment, and having a voice in the development of new risk-based models in oncology.

ACCC Responds to CMS on Proposed 2016 PFS Rule

By Leah Ralph, Manager, Provider Economics and Public Policy, ACCC

Centers_for_Medicare_and_Medicaid_Services_logoOn September 8th, ACCC submitted comments on CMS’ proposed 2016 Physician Fee Schedule rule. This year, the proposed PFS was released later than usual and contained a number of provisions that ACCC will be watching closely in the coming months.

Read on for a quick roundup of major provisions and ACCC recommendations to CMS:

Radiation Oncology Cuts

CMS proposes several significant changes to payment for radiation oncology procedures that would collectively result in drastic cuts for radiation oncology providers – an estimated 3% for radiation oncology and 9% for freestanding radiation therapy centers. CMS is proposing payment rates for new CPT codes that would effectively reduce Medicare reimbursement for IMRT and other radiation treatment delivery services. The agency also proposes to remove several essential direct practice expense inputs from the new radiation treatment delivery codes, including the on-boarding imaging equipment that is essential to providing safe and accurate radiation treatment. Finally, CMS proposes to adjust the equipment utilization rate assumption for the linear accelerator used in image guidance from 50% of available time to 70% of available time over two years, reducing reimbursement for services that make use of that equipment.

In our comments, ACCC expressed significant concern to CMS that these deep, simultaneous cuts in radiation oncology reimbursement will have the effect of forcing some cancer care providers, particularly those operating in rural and underserved areas, to close their doors. ACCC urges CMS to take the necessary steps to mitigate this threat, for example, by not implementing the proposed increase in the equipment utilization rate. ACCC will be monitoring this closely and stands ready to work with CMS to find ways to implement any appropriate changes over a period sufficient to allow providers to absorb the changes while not compromising access to critical radiation oncology services.

 Biosimilar Reimbursement

CMS proposes a payment methodology for biosimilar products in which all biosimilars with the same reference product would be assigned a single HCPCS code and reimbursed based on the volume-weighted average sales price (ASP) for all products under the code plus 6% of the reference product’s ASP.

ACCC asks CMS not to finalize this proposal. We expressed concern that assigning multiple biosimilar products a single HCPCS code would create new and unnecessary administrative burdens for physicians and other providers when treating patients with biosimilar products, as they would not only need to enter the HCPCS code into the medical record, as they do now, but also the specific biosimilar therapy used for the patient. Additionally, this approach could significantly impede effective tracking of safety information and other information about the patient experience with specific biosimilar products—after these enter the market. We urge CMS to promote effective tracing of safety information and to minimize administrative burdens on providers who prescribe biosimilars.

 Advance Care Planning

CMS proposes to establish payment rates for the two CPT codes adopted by the AMA CPT Editorial Panel to describe advance care planning services. ACCC strongly supports this proposal and asks that the payment rates for these services adequately reflect the cost to physicians of providing advance care planning.

As ACCC believes advance care planning services are equally important in the hospital outpatient setting, where they also take substantial time and resources and contribute significantly to the quality of patient care. In our comments to the proposed 2016 Outpatient Prospective Payment System rule, we urged CMS to pay separately for these two CPT codes in the outpatient setting as well.

Chronic Care Management

CMS recognizes that Medicare’s payment rates for the CPT codes for transitional care management (TCM) and chronic care management (CCM) do not fully account for the cognitive work that primary care physicians and other practitioners perform in managing and delivering care, particularly to chronically ill beneficiaries. CMS identifies add-on codes as one potential means of establishing payment rates that appropriately value the additional time and intensity of physicians’ cognitive work often involved in delivering care management services. ACCC encourages CMS to develop such codes, and to work with ACCC and other provider organizations to ensure that any new add-on codes are structured and valued appropriately.

ACCC also has concerns related to CMS’ proposal for chronic care management in the 2016 OPPS proposed rule. On the hospital outpatient side, CMS is proposing to permit only one hospital to bill for CCM services during a calendar month. ACCC points out to CMS that because cancer care is highly multidisciplinary, it can be difficult to agree upon who should be the designated CCM physician, and we are concerned that CMS’ rules for these services already make it very difficult for hospitals to seek payment for them. We urge CMS to continue to consult with hospitals and physicians on the best way to determine which entities should bill for these services.

“Incident To” Services

CMS proposes to require that the physician or other provider who bills for an “incident to” service must also be the physician or other provider who directly supervises the auxiliary personnel in providing that service. If CMS were to finalize this proposal, ACCC urges the agency to provide education to physicians and other providers on the revised requirement to ensure providers do not experience unwarranted disruption in billing for appropriate “incident to” services.

CMS is expected to finalize the 2016 Physician Fee Schedule rule in late October. Stay tuned, as ACCC will keep members updated as CMS revises and finalizes these important proposals.

Proposed 2016 Medicare Rules

Centers_for_Medicare_and_Medicaid_Services_logoBy Leah Ralph, Manager, Provider Economics and Public Policy, ACCC

The Centers for Medicare & Medicaid Services (CMS) 2016 proposed rules are out, and, not surprisingly, we continue to see the agency push outpatient payments toward more bundled services and move full steam ahead to tie Medicare payments at large to quality and value in the coming year.

2016 HOPPS Proposed Rule

Generally speaking, the proposed Hospital Outpatient Prospective Payment System (OPPS) rule includes few surprises, most notably CMS is proposing a -2% across-the-board reduction to compensate for “excessive” packaged payments for laboratory services in CY14. The rule also includes nine new comprehensive ambulatory payment classifications (C-APCs) to add to the 25 introduced last year and proposes consolidation and restructuring of nine APC clinical families. Importantly, CMS will continue to reimburse drugs at ASP+6% in the hospital outpatient department. The agency also provides some flexibility on the “two-midnight” rule. Currently the rule requires that a beneficiary to remain in the hospital for longer than two midnights in order for the stay to be reimbursed as an inpatient stay. Under the proposed rule, CMS would recognize some shorter stays as inpatient, and would evaluate on a “case-by-case” basis.

 2016 PFS Proposed Rule

The proposed Physician Fee Schedule (PFS) rule was released later than expected this year, perhaps due to slightly more contentious provisions. The good news – perhaps – is that, as proposed, the 2016 PFS would have no (0%) impact on Medicare payments in hematology/oncology. However, on the radiation oncology side the news is not so good. If all of the proposals in the rule are finalized, radiation oncology will face an estimated -3% cut and freestanding radiation therapy centers will see a -9% cut due to a combination of new code values and a change in assumption involving the overall use of linear accelerators. CMS also indicates how it will treat biosimilars for the purposes of Part B reimbursement, proposing to assign the same HCPCS code to all biosimilars that reference the same innovator drug. These would be paid based on their volume-weighted ASP+6% of the reference product’s ASP. If no ASP data is available, biosimilars would be reimbursed at 100% of their wholesale acquisition cost.

Under the PFS, CMS also proposes to create two new CPT codes for advanced care planning services, one to start the conversation with a patient and the other for continued discussion. The rule also begins the phasing out of the PQRS (the 2018 payment adjustment will be the last); adjustments for quality reporting will now be made under the new Merit-Based Incentive Program (MIPS), created by the legislation that repealed the Medicare Sustainable Growth Rate (SGR). CMS seeks comments on MIPS on issues like the definition of clinical practice improvement activities, how to define a physician-focused payment model, and more.

ACCC will be submitting comments on both rules, due August 31 and September 8, respectively. On Tuesday, July 21, 4:00-5:00 PM EST, ACCC is hosting a members-only conference call with a full rundown of both proposed rules. Stayed tuned.