Tag: Renee Smiddy

Michigan Dispensing Law Changes

Member News

Michigan state law will be updated beginning March 29, 2023, to allow pharmacists to dispense a non-controlled prescription written by a prescriber licensed in another state or province of Canada. Public Act 80 of 2022 defines ‘prescriber’ as a:

  • Licensed dentist.
  • Licensed Doctor of Medicine.
  • Licensed Doctor of Osteopathic Medicine and Surgery.
  • Licensed Doctor of Podiatric Medicine and Surgery.
  • Licensed physician’s assistant.
  • Licensed optometrist.
  • Advanced practice registered nurse.
  • Licensed veterinarian.
  • Nurse anesthetist.

A pharmacist who dispenses a prescription written by a prescriber licensed in another state or province of Canada must comply with Michigan state law. Pharmacists are not required to determine if an advanced practice registered nurse or physician’s assistant prescriber in another state are authorized under the laws of the other state or province of Canada to issue the prescription.

Members with questions may contact Renée Smiddy at the MHA.

LARA Updates Implicit Bias Training Rules

Member News

The Michigan Department of Licensing and Regulatory Affairs (LARA) recently released the final draft of the Public Health Code – General Rules to allow asynchronous teleconference or webinars as acceptable modality of training as part of the implicit bias training standards. Webinars and asynchronous teleconference were previously prohibited because they didn’t allow for interaction between students and the instructor. These rules will be filed with the Joint Committee on Administrative Rules and become effective March 23, 2023

Under the updated rules, individuals applying to renew their license will be allowed to satisfy the implicit bias training standard through webinars offered by acceptable sponsors. Another positive rule change is the allowance of implicit bias training to satisfy other training or continuing education requirements.

Members with questions should contact Renée Smiddy at the MHA.

CMS Finalizes Rate Cuts in 2023 Medicare Physician Fee Schedule

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released the 2023 Medicare Physician Fee Schedule (PFS) final rule, effective Jan. 1, 2023. The rule reduces the PFS conversion factor by $1.55 (4.7%) to $33.06 in a calendar year (CY) 2023 from $34.61 in CY 2022, which reflects a required statutory update of 0% and the expiration of the one-year Congress-approved 3% increase in PFS payments for CY 2022. The finalized rule also includes changes in policies for telehealth, opioid use disorder, dental services, and the Medicare Shared Savings Program (MSSP).

The CMS finalized:

  • Expanding the telehealth category 3 codes list and extend coverage through Dec. 31, 2023
  • Modifying opioid treatment program payment rates that will increase overall payments for medication-assisted treatment and other treatments for opioid use disorder
  • Clarified that Medicare Fee-For-Service (FFS) payment for dental services when it is an integral part of treatment, such as dental exams and necessary treatment before organ transplants, cardiac valve replacements and valvuloplasty procedures
  • Making several changes to increase participation in the MSSP, including updates to benchmarks to sustain long-term participation and reduce costs. The CMS also updated quality measurement policies, including a new healthy equity adjustment that will award bonus points to accountable care organizations serving high proportions of underserved beneficiaries

Members with questions and feedback should contact Renée Smiddy at the MHA.

Provider Enrollment Requirements Reinstated Effective Dec. 1, 2022

Member News

The Michigan Department of Health and Human Services (MDHHS) issued MMP 22-38 COVID-19 Response: Termination of Bulletin MSA 20-28, which reinstates provider enrollment requirements. The following processes with be reinstated effective Dec. 1, 2022:

  • Community Health Automated Medicaid Processing System (CHAMPS) enrollment revalidations. The MDHHS will begin provider revalidation date notifications starting Nov. 2022.
  • Resume site visits for prospective and current providers.
  • Fingerprint-based criminal background checks.
  • Enrollment application fees. Providers may still request a hardship waiver.

Members with questions should contact Renée Smiddy at the MHA.

MDHHS Releases Proposed Policy to Resume Required Enrollment Activities

Member News

The Michigan Department of Health and Human Services (MDHHS) released a proposed policy to rescind remaining waived provider enrollment (PE) requirements implemented by MSA 20-28 and resume required enrollment activities that were waived during the federal COVID-19 Public Health Emergency (PHE).  The MDHHS proposes to reinstate the following processes beginning Dec. 1, 2022:

  • Community Health Automated Medicaid Processing System (CHAMPS) enrollment revalidations with MDHHS notifying providers beginning November 2022 of their rescheduled validation date, which will be assigned on a rolling basis starting with providers who have had the longest revalidation pause. Providers may view their rescheduled revalidation date in CHAMPS.
  • Site visits for prospective and current providers which will be performed following all state and federal public health guidelines, such as masking and social distancing.
  • Fingerprint-based criminal background checks associated with providers in the high-risk category.
  • Enrollment application fees for providers who had their fees waived under MSA 20-28. Providers may still request a hardship waiver per the Centers for Medicare and Medicaid Services (CMS) guidelines which will only be granted after the MDHHS receives approval from the CMS.

Members are encouraged to review the proposed policy and submit comments to the MDHHS by Oct. 28. Members with questions should contact Renée Smiddy at the MHA.

Member Feedback Requested on Proposed Telemedicine Policy

Member News

The Michigan Department of Health and Human Services (MDHHS) recently released a proposed policy to update Medicaid coverage of telemedicine services after the conclusion of the federal COVID-19 public health emergency (PHE). The policy outlines several updates, including:

  • Making permanent policies established during the PHE through bulletins MSA 20-09 (General Telemedicine Policy Changes) and MSA 21-24 (Asynchronous telemedicine services). MSA 20-09 requires either direct or indirect patient consent for all telemedicine services and defines originating and distant sites. MSA 21-24 clarifies Medicaid coverage for asynchronous telemedicine services, including store and forward services, remote patient monitoring and interprofessional consultations.
  • Not requiring prior authorization unless the equivalent in-person service requires prior authorization. Authorization requirements for Medicaid health plans may vary.
  • Establishing payment rates for allowable telemedicine services at the same level as in-person services. To effectuate this policy, the provider must report the place of service as they would if they were providing the service in-person, along with modifier 95 – Synchronous Telemedicine Service. *MDHHS varies from Medicare telehealth billing by not using place of service 02 or 10 but aligns in the use of modifier 95.
  • Allowing audio-only telemedicine services only for select situations where the beneficiary does not have access to audio/visual capabilities. These codes are currently represented as CPT codes 99441-99443 and 98966-98968.

Members are encouraged to submit comments to the MDHHS by Sept. 20. Questions should be directed to Renée Smiddy at the MHA.

CMS Proposes Rate Cuts in 2023 Medicare Physician Fee Schedule

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule for physician fee schedule (PFS) payments and other Medicare Part B issues, effective Jan. 1, 2023. The rule proposes to reduce the PFS conversion factor by $1.53 (4.6%) to $33.08 in calendar year (CY) 2023, compared to $34.61 in CY 2022. The proposed rule also includes changes in policies for telehealth, opioid use disorder, dental services, and the Medicare Shared Savings Program (MSSP).

The CMS proposes to:

  • Reduce the conversion factor to $33.08, which reflects a required statutory update of 0% and the expiration of the one-year Congress-approved 3% increase in PFS payments for CY 2022.
  • Delay indefinitely the payment penalty period of the Appropriate Use Criteria. The CMS is unable to forecast when the payment penalty phase will begin again.
  • Expand the list of telehealth category 3 codes and extend coverage through Dec. 31, 2023.
  • Delay for one year (until Jan. 1, 2024) implementation of its policy to define the substantive portion of a split (or shared) visit based on the amount of time spent by the billing practitioner.
  • Make several changes to increase participation in the MSSP, including implementing longer glide paths to downside risk for accountable care organizations (ACOs) and modifying benchmarking methodology to ensure ACOs do not have to compete against their own best performance.
  • Expand behavioral health access by permitting licensed professional counselors, marriage and family therapists, and other types of practitioners to provide services, thereby creating an exception to the direct supervision requirement for “incident to” billing.

Members are encouraged to submit comments to the CMS by Sept. 7. Questions and feedback should be directed to Renée Smiddy at the MHA.