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Tags Posts tagged with "Medicare"

Medicare

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On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that announces and solicits public comments on proposed policy changes for Medicare payments under the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) and other Medicare Part B issues, effective on or after January 1, 2024.

The calendar year (CY) 2024 PFS proposed rule is one of several proposed rules that reflect a broader Administration-wide strategy to create a more equitable health care system that results in better access to care, quality, affordability, and innovation.

The proposed modifications include several pertaining to telehealth policy in the Medicare program for 2024. One of the major takeaways from the proposed 2024 PFS is the clarification that certain telehealth flexibilities that were previously extended until 151 days after the end of the public health emergency (PHE) have now been extended until December 31, 2024, in accordance with amendments made by the Consolidated Appropriations Act, 2023. These extensions have been known since the CAA’s passage in December last year and has also been addressed in a series of fact sheets and FAQ documents.

However, there were also some new changes addressed in the 2024 PFS. For example, every year CMS will consider adding new services to their list of codes that are reimbursable via telehealth. While they did not decide to add any new codes on a permanent basis to the list (though many remain on the list temporarily through the end of 2024), they did propose to add a number of codes to Category 3 (CMS’ current temporary list), including certain codes for health and well-being coaching services. Additionally, CMS announced a proposed revision to their telehealth code classification process, moving from a Category 1, 2 and 3 classification system to a binary ‘permanent’ or ‘provisional’ classification in an attempt to simplify the process beginning in CY 2025. In order to make the steps for getting a code accepted for inclusion in either the permanent or provisional telehealth lists transparent, CMS proposes a five-step process that is detailed in the proposed 2024 PFS, which includes consideration of the evidence of clinical benefits.

A few additional changes proposed in the document are listed below:

  • The list of telehealth practitioners is amended to recognize marriage and family therapists and mental health counselors as telehealth practitioners, effective Jan. 1, 2024.
  • CMS will pay for place of service (POS) 10 at the non-facility PFS rate, while 02 will be paid at the facility rate beginning Jan. 1, 2024.
  • Frequency limitation would be removed for subsequent inpatient visits through the duration of CY 2024.
  • Multiple clarifications are provided for billing both remote physiologic monitoring (RPM) and remote therapy monitoring (RTM) codes.
  • Direct supervision is allowed to include real-time audio video interactive telecommunication through Dec. 31, 2024 (including for FQHCs and RHCs). Direct supervision requirements are also addressed for occupational therapists in private practice (OTPP) and physical therapists in private practice (PTPP) for unenrolled physical and occupational therapists when providing remote RTM.

CMS will be accepting comments on their proposals until 5:00 pm EST on September 11, 2023, and RCPA will review the document and work with the National Council for Mental Wellbeing in drafting recommendations. We welcome provider feedback and comments to be included and ask that you contact and share these with your RCPA Policy Director.

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The Centers for Medicare and Medicaid Services (CMS) recently notified the American Medical Rehabilitation Providers Association (AMRPA) that the rollout of the Review Choice Demonstration (RCD) would begin on August 21, 2023, in Alabama. In previous information released about the RCD, Pennsylvania is most likely to be one of the next states in line for this rollout. Under this demonstration, CMS Medicare Administrative Contractors (MACs) will review all Medicare Fee-for-Service (FFS) claims in select states. CMS will utilize a dedicated website to provide updated information and resources to inpatient rehabilitation facility (IRF) stakeholders.

RCPA is working closely with AMRPA staff and will keep members apprised of developments and updates throughout the demonstration. The RCD website confirms that affected IRFs will have the option to elect pre-claim or post-payment review (and must use the same option for all claims).

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The Centers for Medicare and Medicaid Services (CMS) issued a press release announcing an increase in three accountable care initiatives that will grow and provide higher quality care to more than 13.1 million people with Medicare in 2023. The initiatives include:

The Shared Savings Program is the largest accountable care initiative in the country and is a permanent program in Medicare that was established by the Affordable Care Act (ACA). The Shared Savings Program has 456 ACOs and 10.9 million assigned beneficiaries in 2023. While the Shared Savings Program experienced a decrease in the number of ACOs and assigned beneficiaries for 2023, the policies finalized in the calendar year (CY) 2023 Medicare Physician Fee Schedule final rule are expected to grow participation in the program for 2024 and beyond, when many of the new policies are set to go into effect. These policies are expected to drive growth in participation, particularly in rural and underserved areas, promote equity, and advance alignment across the accountable care initiatives, and increase the number of beneficiaries assigned to ACOs participating in the program by up to four million over the next several years.

The ACO REACH Model aims to improve the quality of care for people with Traditional Medicare through better care coordination and by increasing access to accountable care in underserved communities. Innovative features the Model will test include benchmark adjustments to shift payments to better support care for the underserved and enhanced Medicare benefits, including care in the home. In 2023, ACO REACH will increase access to accountable care in underserved populations. The ACO REACH Model will have 824 Federally Qualified Health Centers, Rural Health Centers, and Critical Access Hospitals participating in 2023 — more than twice the number in 2022. Increasing the number and reach of ACOs in underserved communities will help close racial and ethnic disparities that have been identified among people with Traditional Medicare in accountable care relationships.

The KCC Model focuses on coordinating care for Medicare beneficiaries with chronic kidney disease stages 4 and 5 and end-stage renal disease (ESRD). In addition to care coordination, the KCC Model focuses on key areas of concern for this population, including delaying the onset of dialysis and increasing access to kidney transplantation so more patients can live fuller and longer lives.

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In an effort to provide additional information on a new provider type recently announced by the Centers for Medicare and Medicaid Services (CMS), a Medicare Learning Network (MLN) fact sheet was released. This new provider type, Rural Emergency Hospitals (REH), is a new Medicare Part A provider type. Starting January 1, 2023, Medicare will pay for Medicare-enrolled REHs to deliver emergency hospital, observation, and other services to Medicare patients on an outpatient basis. Additional information, including how to become an REH, billing, payment, reporting quality data, etc. is available in the fact sheet.

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Last week, H.R.8746 — Access to Inpatient Rehabilitation Therapy Act of 2022 was introduced to ensure Medicare beneficiaries in inpatient rehabilitation facilities (IRFs) are able to access all skilled, medically necessary rehabilitation therapies that are most appropriate for their condition. This bill, also known as the “three hour rule bill,” would expand the current three hour rule in which Medicare requires IRF patients to be able to participate in, and benefit from, three hours of rehabilitation therapy per day, five days a week (or 15 hours over a seven day period). The current regulation only allows physical therapy (PT), occupational therapy (OT), speech therapy, and orthotics and prosthetics care to count towards the three hour requirement. As a result, many patients have difficulty accessing additional forms of therapy that may be more appropriate.

During the COVID-19 public health emergency (PHE), the three hour rule has been waived in its entirety. If the Access to Inpatient Rehabilitation Therapy Act is enacted, it would ensure that IRFs maintain flexibility after the expiration of the PHE. Most importantly, the legislation would allow certain therapies, including recreational therapy, cognitive therapy, and respiratory therapy, to count towards the three hour rule after the patient’s admission. These additional therapies and skilled modalities would be identified by the Secretary of Health and Human Services (HHS). At the time of admission, the existing three hour rule would still apply, ensuring that IRF admissions do not increase (and thus add to underlying costs for the Medicare program) due to the new flexibility.

This legislative solution has been developed over several years with Members of Congress and a group of stakeholders, including the American Medical Rehabilitation Providers Association (AMRPA), the American Academy of Physical Medicine & Rehabilitation (AAPM&R), the Brain Injury Association of America (BIAA), and the American Therapeutic Recreation Association (ATRA).

For additional information, please refer to Congressman Courtney’s press release.

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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.

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