RCPA Submits Comments to CMS Regarding Physician Fee Schedule for CY 2023
CMS
CMS Releases RFI Seeking Public Input on Accessing Healthcare & Related Challenges
The Centers for Medicare and Medicaid Services (CMS) has released a Request for Information (RFI) that seeks public input on accessing healthcare and related challenges, understanding provider experiences, advancing health equity, and assessing the impact of waivers and flexibilities provided in response to the COVID-19 Public Health Emergency (PHE).
The Make Your Voice Heard: Promoting Efficiency and Equity Within CMS Programs RFI furthers CMS’ commitment to engaging and learning from partners, communities, and individuals across the health system to inform how we can better support the populations we serve. In alignment with Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, the CMS Strategic Plan Pillar: Health Equity, and the CMS Framework for Health Equity (2022–2032), this RFI aims to gather feedback and perspectives related to challenges and opportunities for CMS to embed health equity into their efforts encouraging innovation, reducing burden, and creating efficiencies across the healthcare system.
CMS is seeking to better understand individual and community-level burdens, health-related social needs, and opportunities for improvement that can reduce disparities and promote efficiency and innovation across programs. CMS is requesting information related to strategies that successfully address drivers of health inequities, including opportunities to address social determinants of health and challenges underserved communities face in accessing comprehensive, quality care. For example, challenges accessing care may include understanding coverage options, receiving culturally and linguistically appropriate care, accessing oral health services, and accessing comprehensive and timely healthcare services and medication.
Through this RFI, CMS also seeks to better understand the factors impacting provider wellness and learn more about the distribution of the healthcare workforce. CMS is particularly interested in understanding the greatest challenges for healthcare workers in meeting the needs of individuals, and the impact of CMS policies, documentation, and reporting requirements, operations, and communications on provider experiences.
Comments received in response to the Make Your Voice Heard RFI will be used to identify opportunities for improvement and to increase efficiencies across CMS programs. In addition, CMS hopes to learn how specific programs have benefited providers, practices, and the people served.
CMS encourages comments from all interested stakeholders, in particular, patients and their families, providers, clinicians, consumer advocates, and healthcare professional associations. CMS also encourages comments from individuals serving and located in underserved communities and from all CMS stakeholders serving populations facing disparities in health and healthcare. The RFI is open for a 60-day public comment period.
Comments must be received by November 4, 2022, to be considered.
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CMS Releases RFI Seeking Public Comments on Medicare Advantage Program
The Centers for Medicare and Medicaid Services (CMS) recently released a Request for Information (RFI) requesting public comments on the Medicare Advantage program. CMS is asking for input on ways to achieve the agency’s vision so that all parts of Medicare are working towards a future where people with Medicare receive more equitable, high quality, and person-centered care that is affordable and sustainable, essentially asking for ways to strengthen this program.
CMS’s intent is to better align the Medical Assistance (MA) program with the agency’s vision for Medicare and the CMS Strategic Pillars. CMS is strongly emphasizing the importance of stakeholder comments for this process. This openness to feedback presents MA plans, providers, and other stakeholders an opportunity to inform the agency’s early thinking as it considers potential regulatory actions impacting supplemental benefits, value-based contracting arrangements, risk adjustment, prior authorization, and marketing among other issues.
CMS will accept comments on the RFI until August 31, 2022.
CMS Releases FY 2023 IRF PPS Final Rule
The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2023 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule that was published in today’s Federal Register. Some of the key provisions contained in the final rule are provided below:
Final FY 2023 Payment Updates
CMS estimates overall payments to IRFs will increase by 3.2 percent compared to FY 2022 levels (higher than the 2 percent estimated in the proposed rule). This update is the result of a 4.2 percent update to the IRF market basket reduced by a 0.3 percent productivity adjustment, which is required by law. As a result of this market basket increase and a few small budget neutrality adjustments, the standard payment conversion factor will increase from $17,240 to $17,878. CMS is also adjusting the outlier threshold, which it says will reduce overall payments by 0.6 percent. CMS says the 3.2 percent overall increase will result in $275 million in increased payments to IRFs compared to 2022.
Proposed Expansion of IRF Transfer Policy to Include Home Health Services
CMS issued a Request for Information (RFI) in the proposed rule regarding the potential expansion of the current IRF transfer payment policy to include home health services. For background, IRFs receive a reduced case mix group (CMG) payment rate under the IRF transfer policy when the patient’s discharge occurs earlier than the average length of stay (for that respective CMG and tier) and the patient is discharged to a certain setting (an IRF, acute-care hospital, LTCH, nursing home that takes Medicare and Medicaid payment). The policy currently does not apply to home health.
The RFI in this year’s rule followed a December 2021 Office of Inspector General (OIG) report finding that Medicare could have saved over $993 million had the IRF transfer policy been expanded to include home health services (based on 2017 and 2018 data). The OIG therefore recommends that CMS explore ways to capture early discharges to home health care in the current policy, which CMS referenced in the proposed rule. Following a review of concern cited in stakeholder comments, CMS is not moving forward with any changes to the transfer policy at this time.
IRF Quality Reporting Program Changes & Requests for Information All-Payer IRF-PAI Reporting Proposal
CMS proposed to require collection of the IRF-PAI for all IRF patients, including those without Medicare, beginning with the FY 2025 IRF QRP (with data collection to begin on October 1, 2023). Currently the IRF-PAI is only required to be collected for Medicare Part A (fee-for-service) and Part C (Medicare Advantage) beneficiaries. In response to comments, CMS opted to finalize the proposal but with a revised implementation date. IRFs will now be required to collect IRF-PAIs on all patients, regardless of payer, for the FY 2026 IRF QRP (data collection to begin on October 1, 2024).
RFI on Future QRP Measure Expansions
CMS had issued a Request for Information (RFI) related to measures/concepts for use in the QRP in future years in the proposed rule. The agency specifically requested information on a cross-setting function measure that would include self-care and mobility items, and development of a patient-level COVID-19 vaccination measure. CMS referenced several of AMRPA’s comments, including concerns that IRF stays are typically not long enough to adequately capture COVID-19 vaccination for patients. CMS did not provide a response to comments but affirmed the agency would use the stakeholder feedback to inform future rulemaking.
Clarification for SCOs on Resuming SC In-Person Monitorings
ODP Announcement 22-085 announces clarification for Supports Coordination Organizations (SCO) on resuming Waiver and Targeted Support Management (TSM) Supports Coordination (SC) in-person monitoring. Many adjustments have been made to the Office of Developmental Programs (ODP) policy and operations during the COVID-19 pandemic. Appendix K allowed for SC services to be provided remotely during the pandemic. ODP planned to replace the Appendix K guidance with new requirements detailed in the Intellectual Disability and Autism (ID/A) Waiver renewals and the Adult Autism Waiver (AAW) amendment effective July 1, 2022, to allow for some SC individual monitoring to continue to be completed remotely.
Both the ID/A Waiver renewals and the AAW amendment are pending approval with the Centers for Medicare and Medicaid (CMS). Therefore, ODP is issuing guidance to clarify the expected requirements of individual monitorings performed by SCs. This announcement outlines the updated requirements for SC in-person and remote monitoring and obsoletes that section of Appendix K.
ODP expects SCOs that were unable to meet the June 30 deadline for completing the in-person monitoring for at-risk individuals to continue to follow their plan and communicate with the ODP regional office to ensure that all the priority individuals are seen in-person.
This announcement outlines requirements for SCOs to implement no later than October 1. For additional questions, please contact your appropriate ODP regional office.
CMS Releases First-Ever Home and Community-Based Services Quality Measure Set
The Centers for Medicare & Medicaid Services (CMS) released a State Medicaid Director Letter (SMDL 22-003) providing guidance for the first-ever Home and Community-Based Services (HCBS) Quality Measure Set, the first of two planned guidance documents from CMS.
The HCBS Quality Measure Set is included in the SMDL, starting on page 14. The list of measures includes the NQF number (if applicable), measure steward, and data collection method, as well as information on whether each measure addresses section 1915(c) waiver assurances and/or can be used to assess access, LTSS rebalancing, and/or community integration and HCBS settings requirements.
Most of the measures are derived from consumer surveys; CMS gives states the flexibility to select measures from the consumer survey of their choice from the following validated tools: NCI®-IDD, NCI-AD™, HCBS CAHPS®, and POM®.
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MACs Begin Distributing QRP Non-Compliance Letters
On July 13, 2022, the Centers for Medicare and Medicaid Services’ (CMS) Medicare Administrative Contractors (MACs) distributed notifications to inpatient rehabilitation facilities (IRFs) that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for calendar year (CY) 2021, which will affect their FY 2023 Annual Payment Update (APU). Non-compliance notifications were placed into facilities’ “Certification and Survey Provider Enhance Reports” (CASPER) folders in the Quality Improvement and Evaluation System (QIES) for hospice and skilled nursing facilities (SNFs), and into facilities’ “My Reports” folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs and long-term care hospitals (LTCHs). If a facility received a letter of non-compliance, it may submit a request for reconsideration to CMS via email. The submission deadline is 11:59 pm on August 11, 2022. View the full details and instructions for submission here.
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