April 02, 2020

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Late on Monday, March 30, with the COVID-19 crisis spreading through the country, the Centers for Medicare and Medicaid Services issued a lengthy set of policy changes to help providers better address the growing public health emergency. These new changes, issued as an interim final rule titled “Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency”, are one in a flurry of federal actions in response to COVID-19. CMS is accepting public comments on this rule for 60 days.

The new interim final rule includes many changes to the Medicare and Medicaid payment for health care services and management of some alternative payment models. For Caravan Health, some of the most important changes are more options for virtual care and telehealth, relief for ACO participants managing the pandemic, and increased health system capacity.
 
The highlights are below:

Promoting virtual care and telehealth:

  • New service available: In an effort to make virtual care services available to more Medicare patients, CMS has added Medicare coverage for telephone evaluation and management (E/M), including services provided to a caregiver. While a telephone visit does not fully replace an in-person visit, it could provide needed care while helping to reduce COVID-19 exposure risks. 
  • New telehealth codes available: CMS has added 80 codes that can be delivered through telehealth, including codes for Emergency Department Services, Inpatient and Discharge Management, Intensive Care, Home Visits, Group Psychotherapy, and certain ESRD services. These services, like all telehealth services, require two-way audio-visual real-time communication
  • Equal pay for telehealth and face-to-face visits. In the interest of protecting patients and providers and allowing practices to maintain their revenue, telehealth visits will be paid at the same rate as they would through a face-to-face office visit. Previously, physician groups had raised concerns that they would not be paid an originating site facility fee if patients were seen at home.
  • Expansion of virtual check-ins and e-visits to both new and established patients. Previously, short (5-10-minute) virtual check-ins and e-visits conducted through an online patient portal could only be billed if provided to an established patient. In the interest of making these virtual visits more widely available, this rule allows providers to bill those codes to both new and established patients. This change brings virtual check-ins and e-visits in line with full telehealth visits, which were recently expanded to new patients.
  • More virtual communications services available to RHCs and FQHCs. CMS added new codes to allow more options for RHCs and FQHCs for both new and established patients.
  • Post-acute care telehealth. Several services are now permitted through telehealth for skilled nursing, home health, and hospice care. This includes the face-to-face visits needed for home health certification and the certification and recertification in hospice. CMS also removed the frequency restriction on certain inpatient and nursing facility services via telehealth.
MSSP Financial Reconciliation:
  • Adjusting shared losses to account for the PHE. CMS recognizes that higher than expected costs for COVID-19 treatment could have extreme adverse effects on the finances of Shared Savings Program ACOs. For 2020, CMS will reduce an ACO’s shared losses by the amount calculated with this formula:
Shared Losses * % of year in PHE * % of beneficiaries affected by PHE

The number of beneficiaries affected by the PHE is assumed to be 100% for 2020. For this formula, the PHE started in March 2020.
 
  • Benchmark calculation: CMS will update ACO benchmarks at the end of the performance year as usual. The factors used to update ACO benchmarks will reflect the national and regional trends related to spending and utilization changes during 2020, including any resulting from the PHE for the COVID-19 pandemic.
Quality reporting for Shared Savings Program ACOs:
  • Adjustment to quality scoring. For 2019, CMS will apply the extreme and uncontrollable circumstances policy that allows MSSP ACOs to be assigned the higher of the mean quality score across ACOs or their own quality score. CMS will consider whether this policy should be applied for 2020 and beyond.
Changes to MIPS-APM scoring:
The rule provides relief to participants in MIPS and Alternative Payment Models to account for the circumstances of the COVID-19 PHE.
 
  • MIPS-APM scoring due to extreme and uncontrollable circumstances. For those APMs unable to report quality data for 2019, the following formula applies, and is intended to create a neutral adjustment under MIPS:
  • Cost 0% (no change)
  • Improvement Activities (scored as usual)
  • Quality (0%)
  • Promoting Interoperability (0%)
 
Increasing Health Care Capacity
  • Billing outside the hospital building. During the PHE, hospitals can bill for diagnostic and therapeutic services provided outside the walls of the acute care hospital to their admitted patients. This could include ambulatory surgery centers, inpatient rehabilitation hospitals, hotels, and dormitories. The hospital must exercise “control and responsibility” for providing care.
  • Payment for testing at home: CMS has created a new payment allowance for lab technicians travelling to patient’s home for COVID-19 testing.

More practitioners treating patients: The rule permits more providers will be able to participate in Medicare, including more flexibility for medical residents to deliver services.

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