The Centers for Medicare & Medicaid Services recently released the Medicare Physician Fee Schedule final rule for calendar year 2022, which includes updates to Medicare payments under the schedule and other Medicare Part B issues effective Jan. 1. Provisions of the rule will:
Reduce the conversion factor by $1.31, from $34.89 to $33.58, to accommodate budget neutrality with changes in relative value units and the expiration of the 3.75% payment increase provided in the 2021 Consolidated Appropriations Act.
Extend eligible telehealth services that were added to the Medicare telehealth services list during the COVID-19 public health emergency (PHE) through Dec. 31, 2023. This will allow for more time for stakeholders to gather data and submit support for requesting that services be permanently added to the Medicare telehealth services list.
Implement an in-person visit requirement at least every 12 months to qualify for telehealth service payment.
Include audio-only communications technology when used for telehealth services for the diagnosis, evaluation or treatment of mental health disorders furnished to established patients in their homes under certain circumstances.
Delay the start date for compliance actions related to electronic prescribing of controlled substances to Jan. 1, 2023, and delay the compliance start date for Part D prescriptions written for beneficiaries in long-term care facilities to Jan. 1, 2025.
Delay the penalty phase of the appropriate use criteria program to Jan. 1, 2023, or the Jan. 1 that follows the declared end of the COVID-19 PHE, whichever comes later.
Pay $30 per dose for the administration of the influenza, pneumococcal and hepatitis B virus vaccines, and maintain the current payment rate of $40 per dose for the administration of the COVID-19 vaccines. In addition, make the additional payment of $35.50 for COVID-19 vaccine administration in the home through the end of the calendar year in which the ongoing PHE ends.
Define and clarify policies for split (or shared) evaluation and management visits, which can be billed by the physician or practitioner who provides the substantive portion of the visit.
Allow physician assistants (PAs) to bill Medicare directly for their professional services, reassign payment for their professional services, and incorporate with other PAs and bill Medicare for PA services.
Delay the increase in the quality performance standard Accountable Core Organizations must meet to be eligible to share in savings until program year 2024.
Members with questions should contact Renée Smiddy at the MHA.
The Centers for Medicare & Medicaid Services (CMS) recently released the calendar year 2022 Medicare Physician Fee Schedule proposed rule. The rule proposes a conversion factor of $33.58, a decrease of $1.31 from the calendar year 2021 conversion factor of $34.89. The updated conversion factor is budget neutral to account for changes in relative value units and the expiration of the 3.75% payment increase provided in the 2021 Consolidated Appropriations Act. The proposed rule also includes provisions to expand telehealth for mental health services and include coverage for audio-only services in certain instances. Highlights for the proposed rule include the following:
Telehealth Services: The CMS continues to evaluate the temporary expansion of telehealth services that were added to the telehealth list during the COVID-19 public health emergency. The CMS proposes certain telehealth services remain on the list until Dec. 31, 2023, so there is a glide path to evaluate whether the services should be permanently added to the telehealth list. The agency is proposing including audio-only communication when used for telehealth services for the diagnosis, evaluation or treatment of mental health disorders furnished to established patients in their homes. It is also proposing to require use of a new modifier for services furnished using audio-only communications.
Medicare Shared Savings Program: The CMS is proposing to freeze the quality performance standard for program year 2023 and revise the methodology for calculating repayment mechanism amounts for risk-based accountable care organizations. The Quality Payment Program Fact Sheet provides additional details.
Vaccine Administration Services: The proposed rule includes a comment solicitation to obtain information on the costs involved in furnishing preventive vaccines, with the goal to inform the development of more accurate rates for these services.
Opioid Treatment Program (OTP) Payment Policy: The CMS is proposing to allow OTPs to furnish counseling and therapy services via audio-only interaction after the conclusion of the COVID-19 public health emergency in cases where audio/video communication is not available to the beneficiary.
Electronic Prescribing of Controlled Substances (EPCS): The CMS is proposing certain exceptions to the EPCS, which requires electronic prescribing of controlled substances for schedule II, III, IV and V controlled substances covered through Medicare Part D.
Requiring Certain Manufacturers to Report Drug Pricing Information for Part B: The CMS is proposing to make regulatory changes to implement the new reporting requirements for drug manufacturers with Medicaid Drug Rebate Agreements.
Clinical Laboratory Fee Schedule: The CMS is seeking comments on policies for specimen collection fees and the travel allowances for homebound patients and inpatients (not in a hospital).
Comments on the proposal are due Sept. 13. Members with questions should contact Renée Smiddy at the MHA.
The Federal Communications Commission announced that Round 2 ofthe COVID-19 Telehealth Program application portal will be open from April 29 to May 6. Applications for the program may be filed through a dedicated application portal on the COVID-19 Telehealth Program webpage. Applications will be accepted once the application filing window opens, and all applications will be reviewed after the application filing window has closed. The COVID-19 Telehealth Program supports the efforts of healthcare providers to continue serving their patients by providing reimbursement for telecommunications services, information services and connected devices necessary to enable telehealth during the COVID-19 pandemic. There will be an additional $249.95 million available for Round 2 funding. Members with questions can contact the Universal Service Administrative Company.
The Federal Communications Commission (FCC) announced that it voted March 30 to reopen the COVID-19 Telehealth Program, a $249.95 million federal initiative that builds on the $200 million program established as part of the CARES Act enacted in March 2020. The COVID-19 Telehealth Program is a reimbursement program that allows healthcare providers to receive compensation for telehealth-related expenses with appropriate invoices and documentation. The new application window for the second round of funding is expected to open within 30 days of the order, and the FCC will provide advance notification of that date.
The COVID-19 Telehealth Program was created to help healthcare providers provide connected care services to patients at their homes or mobile locations in response to the COVID-19 pandemic. With the relaunch of the program, the FCC announced that telehealth technology is a vital component of curbing inequities in access to healthcare services and that applications will be evaluated equitably to better ensure each state and territory can be approved for funding. Round 2 funding will prioritize low-income communities, tribal communities, areas with provider shortages and projects that were not approved during the Round 1 application. The second application process will differ from the first by having an application deadline meant to ensure all applications are reviewed, rather than applications being reviewed as submitted. The first round of funding for the program was depleted in July 2020 after issuing awards to 539 applicants. Members with questions should contact Renée Smiddy at the MHA.
As the Thanksgiving holiday approaches, the number of hospitalizations due to COVID-19 continues to rise. The MHA keeps members apprised of pandemic-related developments affecting hospitals through email updates and the MHA Coronavirus webpage. Important updates are outlined below.
Vaccine Studies Show 95% Effectiveness
Moderna announced Nov. 16 that the latest trials and studies of its COVID-19 vaccine show 95% effectiveness, and Pfizer updated its findings Nov. 18, announcing its vaccine also shows 95% effectiveness. Moderna’s results stem from its Phase 3 clinical trial of 30,000 individuals, and Pfizer’s efficacy rate resulted from a final analysis of its trial with more than 41,000 volunteers. Both vaccines use messenger RNA (mRNA) technology to cause the effective immune response. A key difference between the vaccines is that Moderna’s vaccine can be safely stored in freezers at about 25 degrees Fahrenheit (minus 4 degrees Celsius), a temperature easily reached by a normal freezer. The Pfizer vaccine requires ultracold storage only achieved by specialized freezers or dry ice.
Pfizer applied with the Food and Drug Administration for emergency use authorization of its vaccine Nov. 20, and Moderna expects to soon apply for the authorization. Although distribution dates are not yet certain, the Michigan Department of Health and Human Services (MDHHS) has advised that providers should be prepared to accept vaccine by early December to ensure expedient distribution and administration when shipments begin. Members with questions may contact Ruthanne Sudderth at the MHA.
Provider Relief Fund Further Clarified
The U.S. Department of Health and Human Services (HHS) has issued two important clarifications related to Provider Relief Fund (PRF) reporting.
The HHS had previously stated that providers could claim only the value of depreciation for COVID-19-related capital purchases with useful lives of more than 12 months. However, after urging from the American Hospital Association and the MHA, the agency stated that expenses for capital equipment, facilities projects and inventory may be fully expensed in cases where the purchase was directly related to the prevention, preparation for and response to COVID-19. Examples of such purchases include:
Upgrading heating, ventilation and air conditioning systems to support negative pressure units.
Retrofitting COVID-19 units.
Enhancing or reconfiguring intensive care unit capabilities.
Leasing or purchasing temporary structures to screen and/or treat patients.
Leasing permanent facilities to increase hospital capacity.
The HHS also clarified that providers’ reporting of net patient revenue should NOT include payments received from or made to third parties that relate to care not provided in 2019 or 2020.
COVID-19 ICU Best Practices Follow-Up Webinar Offered Nov. 24
A Nov. 11 COVID-19 webinar titled “ICU Management & Treatment of COVID-19 Patients” was hosted under the MI-COVID19 registry continuous quality improvement initiative and provided meaningful discussion for participants. As a result, a follow-up webinar has been scheduled for noon to 1 p.m. EST Nov. 24. Objectives include:
Summarizing the latest COVID-19 intensive care unit (ICU) guidelines and recommendations.
Discussing best practices for management of critically ill COVID-19 patients.
Identifying resources and creating a network for ICU leaders in Michigan to advance the care of critically ill COVID-19 patients.
CDC Offers Education on Telehealth and Health Equity Dec. 8
The Centers for Disease Control and Prevention (CDC), through its Clinician Outreach and Communication Activity division, will host an educational event via Zoom from 2 to 3 p.m. EST Dec. 8 that will focus on telehealth and health equity. Details and access information for the event are available online. Presenters from Kaiser Permanente and the Veterans Health Administration will discuss how telehealth has affected health equity in their patient populations before and during the COVID-19 pandemic.
Topics will also include challenges and opportunities related to telehealth implementation. Presenters will share strategies to expand access that can reduce disparities and improve culturally responsive care to help achieve health equity within each organization. In addition, presenters from the CDC will share telehealth strategies that incorporate the CDC’s frameworks for Addressing Health Equity in Public Health Practice.
In associated news, the MHA recently released its Pledge to Address Racism and Health Inequities that was approved by the MHA Board of Trustees at its Nov. 4 meeting (see related article).
COVID-19 Relief Facility Application Now Open
The state has released the application for being designated a COVID-19 Relief (CR) Facility, which are designed to allow eligible Nursing Facilities to retain COVID-19-positive residents. These facilities will meet criteria established in Senate Bill 1094 to care for COVID-19-positive residents who become ill and do not require hospital-level care. The purpose of the CR Facilities is to provide care in place with enhanced infection control measures for individuals with confirmed COVID-19 who have not met the criteria for discontinuation of Transmission-Based Precautions and have limited access to the state’s Care and Recovery Centers. All approved CR Facilities may retain, or readmit after acute care, their own COVID-19-positive residents.
Facilities must meet certain criteria to qualify for CR Facility designation or admission of new COVID-19-positive residents, as detailed in Bulletin Number MSA 20-73 from the Medical Services Administration. The bulletin also provides a list of documents and details applicants should have prepared before applying.
Completed applications should be submitted by 5 p.m. Dec. 1. The MDHHS, in partnership with the Michigan Department of Licensing and Regulatory Affairs, will review applications as they are received. Notification of application status will be contingent upon the volume of applications received. However, it is estimated that facilities seeking CR Facility designation may expect to be notified about the determination within one to two weeks of application submission. Questions about CR Facilities may be submitted to the MDHHS via email.
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Telehealth improves not only access to care, but also health outcomes, by removing barriers of time and distance. COVID-19 has transformed telehealth from a desirable program into an essential element of care delivery. The implementation of telehealth can be costly and challenging, but with the right approach, hospitals can embrace this healthcare technology.
The MHA Health Foundation webinar Implementing a Successful Rural Telehealth Program will identify ways to assess the positive impact telehealth can have on the population a hospital serves, outline goals that can be achieved with telehealth, offer criteria for selecting the telehealth program that best fits the organization and more.
The webinar is scheduled from 2 to 3 p.m. EDT Sept. 1, and MHA members can register for a $195 connection fee. Members with questions should contact Erica Leyko at the MHA.
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“Primary care gatekeeping featuring whole-person care in tandem with capitated payments by health insurers and large employers is gaining momentum. It’s also gaining traction in states that offer Medicaid managed care plans and in Medicare Advantage plans that now serve 27 million seniors. … It’s understandable: chronic diseases account for 75% of health spending in the U.S. system and a third of these can be mitigated through aggressive primary care gatekeeping."
Telehealth improves not only access to care, but health outcomes by removing barriers of time and distance. COVID-19 has transformed telehealth from a desirable program to an essential element of care delivery. Although the implementation of telehealth can be costly and challenging, with the right approach, hospitals can embrace this healthcare technology.
The MHA Health Foundation webinar Implementing a Successful Rural Telehealth Program will identify ways to assess the positive impact that telehealth can have on the population the hospital serves, outline goals and criteria for selecting a telehealth program, and more.
The webinar is scheduled from 2 to 3 p.m. EDT Sept. 1, and MHA members can register for a $195 connection fee. Members with questions should contact Erica Leyko at the MHA.
The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule for the Medicare fee-for-service physician fee schedule (PFS) payments, effective Jan. 1, 2021. The proposed rule would update the PFS rates and implement year five of the quality payment program created by the Medicare Access and CHIP Reauthorization Act of 2015. The CMS proposes to:
Reduce the conversion factor to $32.26, with the budget neutrality adjustment to account for changes in relative value units, as required by law. This would be a decrease of $3.83, or 10.6%, from calendar year 2020.
Add services to the Medicare telehealth list of services and make other changes to retain certain COVID-19 telehealth flexibilities.
Increase payment rates for office/outpatient evaluation and management visits.
Expand supervision of diagnostic tests by certain nonphysician practitioners.
Delay the next Clinical Laboratory Fee Schedule (CLFS) data reporting period by one year so that hospital outreach laboratories would not need to report private payer data before the Jan. 1 through March 31, 2022, time period.
Eliminate the phase-in of CLFS payment cuts through calendar year 2024.
Align the Medicare Shared Savings Program reporting requirements with Meaningful Measures to reduce reporting burden and focus on patient outcomes. Automatic full credit for Consumer Assessment of Healthcare Providers and Systems patient experience of care surveys will be provided for performance year 2020. More information is available on the Quality Payment Program fact sheet, which can be downloaded from the Quality Program Resource Library on the CMS website.
Implement provisions of the Substance Use disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act, including Medicare coverage for opioid treatment programs, screening for substance use disorder in Medicare physicals and electronic prescribing of controlled substances.
The CMS will accept comments on the proposed rule through Oct. 5. The agency has waived its typical timeline for releasing the final rule, which may result in release of the final rule as late as Dec. 2 for the Jan. 1, 2021, effective date. Members with questions should contact Renée Smiddy at the MHA.