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CMS

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Photo by Markus Winkler on Unsplash

CMS sent out QSO-21-14 this week. It gives some extensive expectations on visitation (outdoor, indoor, virtual, compassionate care), COVID-19 testing of staff/clients/visitors, communal dining and activities, survey considerations, and recommended resources. Additionally, Kevin Dressler sent the following updates:

Incident Management Bulletin

Reminder: We sent out the draft IM bulletin a few months ago and have not received any feedback. I would love to hear everyone is fine with the way the IM bulletin is written; however we fully expect some comments. The Bulletin mirrors the IM bulletin for the 6400 covered locations for the private ICFs and has some increased requirements for the public ICFs (state centers).  Please send all comments to Chris Blauser by March 15, 2021. Thank you.

Vaccine Administration

We want to verify that all ICFs have established a provider to administer COVID vaccines to the people served and staff at each of your ICF locations; if you do not have a provider identified, we can assist in locating a provider for you.

  • Please identify any ICF location in your organization that has not established a provider to administer the COVID-19 vaccination to the staff and people supported. If an ICF location meets this criteria, please send an email IMMEDIATELY with location information for assistance connecting with a vaccine provider.

Health Alert Network Updates

Please review the updated Health Alert Network guidance from the PA Department of Health. I listed some of the recent updated or newly developed HANs that may be of interest:

  • HAN 551 – Post Vaccine Quarantine Guidance
  • HAN 550- COVID variant update
  • HAN 547- Antigen Testing for COVID-19 in Long Term Care Facilities
  • HAN 545- Vaccination Indicators and Contraindications

ICF Task Force Meeting Proposed Dates

The meetings for 2021 will be video conferencing through Skype or Microsoft Teams.

Proposed Dates and times:

  • March 2, 2021 (Tue)  11-1pm
  • July 6, 2021 (Tue)  11-1pm
  • November 2, 2021 (Tue)  11-1pm

Let us know if there are any major conflicts with dates.

ICF Taskforce Meeting Topics

As always we would like to make the ICF Task Force Meetings as meaningful as possible.  So, please submit to us any topics and ideas that would be of value to you and your organization and we will work to incorporate them into the meetings.

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The Centers for Medicare and Medicaid Services (CMS) has released an Interim Final Rule with Comment Period that will establish a new COVID-19 treatments add-on payment (NCTAP) under the Medicare Inpatient Prospective Payment System (IPPS), which is effective from November 2, 2020, until the end of the Public Health Emergency (PHE) for COVID-19. To mitigate potential financial disincentives for hospitals to provide new COVID-19 treatments during the COVID-19 PHE, the Medicare program will provide an enhanced payment for eligible inpatient cases that involve the use of certain new products with current Food and Drug Administration (FDA) approval or emergency use authorization to treat COVID-19. Comments will be accepted until the close of business on January 4, 2021.

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The Centers for Medicare and Medicaid Services (CMS) issued Medicare Learning Network (MLN) Matters article MM12063 entitled “Calendar Year (CY) 2021 Update for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Fee Schedule”. It becomes effective on January 1, 2021. This article includes material on the data files, update factors, and other information related to the update of the fee schedule. The DMEPOS fee schedule is updated on an annual basis. For CY 2021, an update factor of 0.2 percent is applied to certain DMEPOS fee schedule amounts. Additional details specific to supplies are provided in the article.

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To further support clinicians during the COVID-19 Public Health Emergency (PHE), the Centers for Medicare and Medicaid Services (CMS) has extended the 2020 Merit-Based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances Exception application deadline until February 1, 2021.

For the 2020 performance year, MIPS eligible clinicians, groups, and virtual groups can submit an application requesting for CMS to reweight one or more performance categories to zero percent due to the current COVID-19 PHE. If members have concerns about the effect of the COVID-19 PHE on your performance data, including cost measures, submit an application and cite COVID-19 as the reason for your application.

For additional information, consult the following resources:

  • MIPS Extreme and Uncontrollable Circumstances Exception Application User Guide and Fact Sheet
  • How to Submit an Extreme and Uncontrollable Circumstances Exception Application Video
  • Extreme and Uncontrollable Circumstances Exception Webpage
  • Quality Payment Program Exceptions Application Fact Sheet

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The Centers for Medicare and Medicaid Services (CMS) has announced that they will hold a call on December 10, 2020 from 1:30 pm – 3:00 pm Eastern Time (ET) that will focus on the calendar year (CY) 2021 Medicare Physician Fee Schedule (MPFS) final rule that was recently released. This call will focus specifically on four key areas within this final rule, including:

  • Extending telehealth and licensing flexibilities beyond the public health emergency (PHE);
  • Updating Evaluation and Management (E/M) coding guidance;
  • Updating the Quality Payment Program and Merit-Based Incentive Payment System Value Pathways; and
  • Updating opioid use disorder and substance use disorder provisions.

During the call, CMS experts will briefly cover provisions from the final rule and address any questions. Members are encouraged to review the final rule prior to the call. To participate, please register here.

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The Centers for Medicare and Medicaid Services (CMS) has planned a special open-door forum to discuss the final rule that was released on November 20, 2020. This final rule clarified the regulations that interpret the federal physician self-referral law (known as the Stark Law). It supports CMS’s “Patients Over Paperwork” initiative by reducing unnecessary regulatory burdens on physicians and other health care providers. It also reinforces the Stark Law’s goal of protecting patients from unnecessary services and the practice of being led to less convenient, lower quality, or more expensive services because of a physician’s financial self-interest. This final rule will be published in the December 2, 2020 Federal Register.

Agenda topics for this special call include:

  • Exceptions that Facilitate the Transition to Value-Based Care Delivery and Payment Arrangements
  • New Guidance and Clarifications Related to Key Terminology of the Stark Law
  • Flexibilities to Enhance Compliance and Reduce Burden

This open-door forum will be held on December 2, 2020 from 2:00 pm – 3:00 pm Eastern Time. To participate, use the information below:

Dial-In Number: 1-888-455-1397

Participant Passcode ID #: 2037400

A transcript and audio recording of this open-door forum will be posted to the Podcast and Transcripts webpage.

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The Centers for Medicare and Medicaid Services (CMS) has released a video tutorial for providers in Inpatient Rehabilitation Facilities (IRFs) with standardized data assessment guidance and assessment strategies for the cognitive assessment—known as the Brief Interview for Mental Status (BIMS). The video is approximately 22 minutes in length and is designed to provide targeted guidance for accurate coding by using live action patient scenarios.

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