CMS Proposes to Allow APM Entities to Submit Applications for the Extreme and Uncontrollable Circumstances Exception; Applications are Due December 31

In the 2021 Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM), the Centers for Medicare & Medicaid Services (CMS) proposed to allow APM Entities to submit an application to reweight Merit-based Incentive Payment System (MIPS) performance categories as a result of extreme and uncontrollable circumstances. We intend to allow APM Entities to submit applications now, but CMS will not be able to make final determinations on applications until and unless the policy proposal is finalized.

If the policy is finalized and an APM Entity’s application is approved, that APM Entity would receive a final score equal to the performance threshold for the 2020 MIPS performance year, and the MIPS eligible clinicians in the APM Entity group would receive a neutral payment adjustment in 2022.

Who is Eligible to Submit an Application?

If the policy is finalized, then APM Entities affected by extreme and uncontrollable circumstances in the following models would be able to submit an application:

  • Medicare Shared Saving Program
  • Next Generation ACO Model
  • Vermont Medicare ACO Model
  • Comprehensive Primary Care Plus (CPC+)
  • Comprehensive ESRD Care (CEC)
  • Bundled Payments for Care Improvement (BPCI)
  • Oncology Care Model (OCM)
  • Maryland Primary Care Program
  • Independence at Home Demonstration

What are the Application Requirements?

Unlike those who choose to apply as individual clinicians, groups, or virtual groups, APM Entities must apply to reweight all MIPS performance categories to 0%. Additionally, 75% of the MIPS eligible clinicians in the APM Entity must qualify for reweighting in the MIPS Promoting Interoperability performance category. They may qualify automatically or through a MIPS Promoting Interoperability Hardship Exception Application.

CMS does not require APM Entities to submit documentation with their applications. However, APM Entities should retain documentation of the circumstances supporting their application for their own records in the event they are selected by CMS for data validation or an audit.

When are Applications Due?

Applications are due to CMS by Thursday, December 31, 2020, at 8:00 p.m. ET.

How do I Apply?

New for 2020: You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you register for a HARP account, sign in to qpp.cms.gov, select ‘Exceptions Applications’ on the left-hand navigation, select ‘Add New Exception,’ and select ‘Extreme and Uncontrollable Circumstances Exception.’

How do I Know if I’m Approved?

If you submit an application and this policy is finalized to allow APM Entities to apply, then you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but it may not appear in the tool until the submission window is open in 2021.

Will Submitting Data Void the Exception?

Data submitted for an APM Entity will not override performance category reweighting from an approved application. This differs from the policy for individual, group, and virtual group applications.

Will an Approved Application Affect Model-Specific Reporting Requirements?

If the policy is finalized and an APM Entity’s application is approved, the approval would only affect MIPS reporting, and that APM Entity would still be required to meet its model-specific reporting requirements.

For More Information

Questions?

Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.

Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

2020 Extreme and Uncontrollable Circumstances Exception and Promoting Interoperability Hardship Exception Applications are Due December 31

Extreme and Uncontrollable Circumstances Application & COVID-19

The COVID-19 pandemic has impacted all clinicians across the United States and territories. However, CMS recognizes that not all practices have been impacted by COVID-19 to the same extent. For the 2020 performance year, CMS will be using our Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency.

If you have any concerns about the effect of the COVID-19 pandemic on your performance data, including cost measures, for the 2020 performance period, submit an application now and be sure to cite COVID-19 as the reason for your application.

If you have an approved application, you can still receive scores for the quality, improvement activities and Promoting Interoperability performance categories if you submit data. If the cost performance category is included in your approved application, you will not be scored on cost measures even if other data are submitted.

Learn more in the 2020 Exceptions Applications Fact Sheet.

Note: CMS has proposed to allow APM Entities to submit an application to reweight MIPS performance categories as a result of extreme and uncontrollable circumstances, such as the public health emergency resulting from the COVID-19 pandemic. Learn more in the 2021 Quality Payment Program Proposed Rule Overview Fact Sheet.

MIPS Promoting Interoperability Hardship Exceptions

MIPS eligible clinicians, groups, and virtual groups may qualify for a re-weighting of the Promoting Interoperability performance category to 0% if they:

  • Are a small practice;
  • Have decertified EHR technology;
  • Have insufficient Internet connectivity;
  • Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues; or
  • Lack control over the availability of CEHRT.

Note: If you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply.

How do I Apply?

New for 2020: You must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself, or another MIPS eligible clinician, group ,virtual group or APM Entity.  For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you register for a HARP account, sign in to qpp.cms.gov, select ‘Exceptions Applications’ on the left-hand navigation, select ‘Add New Exception,’ and select ‘Extreme and Uncontrollable Circumstances Exception’ or ‘Promoting Interoperability Hardship Exception.’

How do I Know if I’m Approved?

If you submit an application for either of the exceptions, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but may not appear in the tool until the submission window is open in 2021.

For More Information

Questions?

Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.

  • Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

 

 

Rural Health Clinics Increase Access to COVID-19 Testing

As COVID-19 swept across America, Congress and the Trump Administration quickly recognized that Rural Health Clinics (RHCs) would be an important source of testing for the new virus. In early May, Congress approved a $225 Million RHC COVID-19 Testing Program so all RHCs could assist with a national effort to increase COVID-19 testing.

The Federal Office of Rural Health Policy (FORHP) was charged with organizing the distribution of this money to RHCs. Through an unprecedented level of collaboration between FORHP, the National Association of Rural Health Clinics (NARHC) and the National Organization of State Offices of Rural Health (NOSORH), this money began flowing to virtually every RHC in the country in a matter of weeks.

Join the leaders of NARHC, NOSORH and FORHP as they discuss both the triumphs of RHCs during COVID-19 and the challenges ahead as we head into a winter resurgence in cases. After brief remarks from each of the rural health leaders, the lines will be opened for you to ask questions and share your experiences with the panelists and attendees. They want to hear about your success as well as what challenges you continue to face in meeting the healthcare needs of your communities in these challenging times.

This Town Hall will also serve as a kick-off to a week-long celebration of the Power of Rural culminating in National Rural Health Day on November 19th! 

Date of Webinar: Monday, November 16th, 2020
Time: 1:00 PM Central

Hosted by the leaders of NARHC, NOSORH, and FORHP

Speakers

  • Tom Morris, MPA, Associate Administrator for Rural Health Policy, HRS, HHS
  • Lindsey Nienstedt, MPH, MSW, Public Health Analyst, FORHP, HHS
  • Bill Finerfrock, Executive Director of NARHC
  • Teryl Eisinger, Executive Director of NOSORH

This webinar is being provided free of charge. However, you must register in advance. If you have issues registering and are using Internet Explorer, try using another browser. If you continue to have issues, please contact us and we will assist you, 866.306.1961.  

To register, go to: https://attendee.gotowebinar.com/register/546882101207560208 or http://bit.ly/RHCs_Increase_COVID_Testing

When the webinar begins you will be connected to audio using your computer’s speakers.

A copy of the slides and a recording will be available within a few days after the webinar is complete at: https://www.narhc.org/narhc/TA_Webinars1.asp

If you have any questions about registering please email us at asst@narhc.org.

IFC-4 and COVID-19 Vaccine Toolkits Listening Session Invitation

On October 28, 2020, the Centers for Medicare & Medicaid Services (CMS) issued an Interim Final Rule with Comment Period (IFC) that removes administrative barriers to eliminate potential delays to patient access to a lifesaving vaccine. In addition, the rule:

  • Creates flexibilities for states maintaining Medicaid enrollment during the COVID19 PHE;
  • Establishes enhanced Medicare payments for new COVID-19 treatments;
  • Takes steps to ensure price transparency for COVID-19 tests, and
  • Provides an extension of Performance Year 5 for the Comprehensive Care for Joint Replacement (CJR) model; and
  • Creates flexibilities in the public notice requirements and post-award public participation requirements for a State Innovation Waiver under Section 1332 of the Patient Protection and Affordable Care Act during the COVID-19 PHE.

The CMS Kansas City office is hosting two 1-hours conversations with sessions CMS staff regarding IFC-4 and the COVID-19 Vaccine Toolkits. They will provide a brief overview of IFC-4 and look at the resources available in the COVID-19 Vaccine Toolkits. Following the overview, the lines will open up to answer questions and listen to feedback.  Information presented will be the same at both sessions; however, the listening portion will be unique to each session.

To register for the November 9 session from 10:00 – 11:00 AM CST, please click on the link here: https://www.eventbrite.com/e/registration-cms-kc-ifc-4-covid-19-vaccine-toolkits-listening-session-tickets-127913156695

To register for the November 10 session from 4:00 – 5:00 pm CST, please click on the link here: https://www.eventbrite.com/e/registration-cms-kc-ifc-4-covid-19-vaccine-toolkits-listening-session-tickets-127927874717

Register for the session that works best for you or both if you are interested in hearing questions and feedback during both sessions. After you register, you will be provided a link to access your session(s). It is strongly encouraged to review the IFC and toolkit prior to the conversation. The IFC can be found at https://www.cms.gov/files/document/covid-vax-ifc-4.pdf and the toolkits can be found at https://www.cms.gov/covidvax.

Webinar Recording: Negotiating the Requirements of Pricing Transparency

Exceeding Patient Expectations and How to Use Pricing as a Competitive Weapon 

Effective January 1st, 2021, every hospital must make available two files for public consumption. The first file must detail a listing of 300 shoppable services. The second file must be a comprehensive file that makes public all standard charge information for all hospital items and services. To ensure that your hospital has an effective and satisfactory platform to address January 2021 expectations, Warbird Revenue Cycle Optimization has created a complimentary educational webinar that reviews the 2020 Pricing Transparency Final Rule’s requirements and scope. Within the webinar, focus is placed upon steps and strategies that will allow you to make pricing transparency a competitive advantage and exceed patient expectations. 

Webinar addresses the following:  

  • Review the 2020 Pricing Transparency Final Rule, effective January 1, 2021 
  • Discuss the logic behind the requirements and expectations 
  • Review component definitions 
  • Detail file formats and requirements 
    • Comprehensive File 
    • Shoppable Services 
  • Provide “Tales from the Field” 
    • Issues 
    • Best Practices 
  • Review “Action Items to Optimize Results” 
  • Address Frequently Asked Questions

Click to view Webinar Recording.

CMS Provides Transparency on Cost and Quality in State Medicaid and CHIP Programs

November 2, 2020

The Centers for Medicare & Medicaid Services (CMS) released the third annual update to its Medicaid and Children’s Health Insurance Program (CHIP) Scorecard. The Scorecard is the signature Medicaid accountability initiative that highlights state and federal performance on the administration and health outcomes of the Medicaid and CHIP programs that collectively account for approximately $600 billion in annual spending and serve over 74 million Americans. For the first time, the Scorecard now provides identified per capita spending data across all states, highlighting variation in program costs alongside the quality and performance data. First released in 2018, the Medicaid and CHIP (MAC) Scorecard is a key part of President Trump’s efforts to ensure greater transparency and accountability of the nation’s largest health coverage programs.

“From the beginning of his administration, President Trump has made giving states more flexibility to provide high quality accessible care for our most vulnerable citizens on Medicaid and CHIP a priority,” said Administrator Seema Verma. “At the same time, we also recognize that with greater autonomy must come greater accountability. The Medicaid and CHIP Scorecard provides unprecedented transparency on cost and quality across state Medicaid and CHIP programs.”

This year’s release builds on the success of the previous Scorecards with a variety of updates and improvements for users, including the debut of a new way to view state-specific data on the Medicaid.gov State Profile “Quality of Care” section. CMS has also improved the overall design and navigation across the 2020 MAC Scorecard to enhance the user experience.

The Scorecard includes healthcare quality measures of asthma medication management for children and adults as well as a measure of follow-up care for adults after an emergency department visit for mental illness. It also contains new administrative accountability measures including CMS and state approval times for managed care contract reviews; and CMS approval times for enhanced federal funding to support states’ eligibility, enrollment and information technology systems.

The 2020 Scorecard provides per capita expenditure data across all states. For the 2018 T-MSIS based per capita expenditure data, seventeen states had a high level of data usability, and an additional eleven states showed a moderate level of data usability. The remaining states fell into the category of having a low level of data usability. The median per capita expenditures, based on CMS calculations, for all states in 2018 is $8,126, with a range of $1,807 in Puerto Rico to $14,387 in North Dakota.[1]  

This year, new data were added to the MAC Scorecard’s National Context page. For example, these new data show the percentage of each state’s population that is enrolled in Medicaid, which ranges from 9.0% to 36.3 % and that nationally, about half of those enrolled in Medicaid and CHIP are children. The National Context page also has new data on the national percentage of beneficiaries enrolled in Medicaid and CHIP by eligibility group and the national rate of improper payments in Medicaid and CHIP.

Further, the national context now provides information on the percentage of Medicaid beneficiaries currently enrolled in Medicare (i.e., dually eligible beneficiaries); the percentage of dually eligible beneficiaries in programs that integrate the delivery of Medicare and Medicaid benefits; and the approval status for states’ transition plans for home and community-based services. For example, nearly half of all states (23) have a Medicaid population where 11.8%-24.2% are dually eligible beneficiaries and 36 states now enroll dually eligible beneficiaries in integrated care programs. The addition of these new data in the Scorecard help to further underscore the importance of understanding the dually-eligible population’s role in the Medicaid program.

CMS continues to engage stakeholders in identifying enhancements to the MAC Scorecard, including receiving input from Medicaid agencies through a collaboration with the National Association of Medicaid Directors.

CMS analyzed trends in median state performance on a subset of Child and Adult Core Sets measures that are included in the MAC Scorecard’s State Health System Performance pillar. Under this pillar, five states reported all measures in Federal Fiscal Year (FFY) 19: Connecticut, Massachusetts, New Hampshire, Tennessee and Washington. Across all states that reportedperformance improved from FFY 2017 to FFY 2019 on several measures, suggesting progress in the quality of care provided to Medicaid and CHIP beneficiaries. These measures include:

  • Well-Child Visits in the First 15 Months of Life (performance improved from 60.2% to 65.1%)
  • Adolescent Well-Care Visits (performance improved from 44.9% to 50.7%)
  • Immunizations for Adolescents (performance improved from 74.5% to 79.2%)
  • Percentage of Eligibles Who Received Preventive Dental Services (performance improved from 48.2% to 49.0%)
  • Comprehensive Diabetes Care: Hemoglobin A1c Poor Control (performance improved from 40.9% to 38.3%). Lower rates are better for this measure.

Overall, under the State Health System Performance pillar, states that reported for FFY19 have opportunities to improve in measures such as: emergency department utilization rate for children and adolescents; the percentage of children ages 3 to 6 who had at least one well-child visit with a primary care provider; the percentage of women delivering a live birth who had a timely postpartum care visit; and inpatient hospital admission rates for short-term complications of diabetes (e.g., diabetic ketoacidosis, hyperosmolarity) in adults ages 18 and older.

The State and Federal Administrative Accountability pillar measures show, for example, that the percentage of State Plan Amendments and 1915 waivers approved in within the first 90 day review period has increased between 2016 and the second quarter of 2020.

When viewing data in the MAC Scorecard, CMS would caution against making direct state-to-state comparisons based solely on data presented. For example, for measures drawn from Child and Adult Core Set, reporting methods can vary among states. States have access to different data on populations covered under fee-for-service as compared to populations covered under managed care. This variation in data availability can impact measure performance. Users should review the state-specific measure notes to better understand states’ reported rates. CMS is committed to working with states to improve standardized measure calculation and reporting which will increase the ability to do direct state-to-state comparisons in the future.

CMS is committed to working with states to improve standardized measure calculation and reporting on measures across the Scorecard. As with other measurement-focused initiatives, CMS offers states technical assistance and quality improvement opportunities to assist states in collecting and reporting measures displayed in the Scorecard, as well as sharing best practices to support improved state performance.

To view the 2020 MAC Scorecard, please visit: https://www.medicaid.gov/state-overviews/scorecard/index.html  

For more information pertaining to the 2020 MAC Scorecard, please visit: 

https://www.medicaid.gov/media/file/2020-medicaid-chip-scorecard-factsheet.pdf

CMS Model Helps Address the Health-Related Social Needs for over 750,000 Medicare and Medicaid Beneficiaries

October 2, 2020

In June, CMS Administrator Seema Verma issued a call to action, noting that “the transition to a value-based system has never been so urgent. When implemented effectively, it encourages clinicians to care for the whole person and address the social risk factors that are so critical for our beneficiaries’ quality of life.”

As part of CMS’s focus on delivering better health care value, for the first time, CMS is sharing a fact sheet with a snapshot of the data from the Accountable Health Communities (AHC) Model, reflecting the agency’s most comprehensive collection of social needs data to date. One in three beneficiaries (33 percent) reported at least one core health-related social need. Food needs were the most commonly reported (67 percent of those reporting at least one need), followed by housing (47 percent), transportation (41 percent), and utility assistance (28 percent). Of those screened, 18 percent were eligible for community navigation services, and 76 percent of eligible beneficiaries accepted the navigation assistance.

The AHC Model addresses a critical gap between clinical care and community services in the current health care delivery system by testing whether systematically identifying and addressing the health-related social needs of Medicare and Medicaid beneficiaries’ through screening, referral, and community navigation services will impact health care costs and reduce health care utilization. The participants in the AHC Model include urban and rural communities and a variety of care settings, ranging from hospitals to primary care to behavioral health providers, with a shared commitment to addressing health-related social needs and connecting beneficiaries to community resources.   

The fact sheet provides information on how the model is implemented and a snapshot of data on demographics of beneficiaries participating in the model as well as their self-reported health-related social needs. The first AHC Model evaluation report is anticipated in 2021 and will include a more in-depth analysis of data from the AHC Model. This fact sheet is for informational purposes only. Learn more in the AHC Model Fact Sheet: First 750,000 Completed Screenings.

WEBINAR: RHC COVID-19 Testing Program Reporting Process & Requirements

On October 6, 2020, at 2:00 pm Eastern, we will be hosting the next Rural Health Clinic Technical Assistance webinar on the RHC COVID-19 Testing Program Reporting Process and Requirements.

Nathan Baugh, Director of Government Affairs, will walk attendees through the reporting process which will be done online. After the presentation, there will be plenty of time for a question and answer period.

This webinar is being provided free of charge. However, you must register in advance. If you have issues registering and are using Internet Explorer, try using another browser. If you continue to have issues, please contact us and we will assist you, 866.306.1961.

Date of Webinar: Tuesday, 10/06/20
Time: 2:00 pm Eastern

Once you register, you will be sent a unique log-in link to use the day of the webinar. Be sure to click on the link allowing the webinar information to be placed into your calendar.

Please feel free to have other clinics or staff you feel may benefit from listening to this webinar to register as well.

To register, go to: https://attendee.gotowebinar.com/register/831949181693245708

When the webinar begins you will be connected to audio using your computer’s speakers.

A copy of the slides and a recording will be available within a few days after the webinar is complete at: https://www.narhc.org/narhc/TA_Webinars1.asp

If you have any questions about registering please email us at asst@narhc.org.

We look forward to having you join us for this important program.

Sincerely,

National Association of Rural Health Clinics

HRSA Issues Proposed Rule to Ensure Affordable Access to Lifesaving Medications

September 24, 2020

The U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), released a notice of proposed rulemaking (NPRM) to increase access to affordable insulin and injectable epinephrine for low-income Americans in health centers nationwide.

“The Health Center Program provides preventive and primary care services to nearly 30 million medically underserved people annually, including more than 2.7 million people with diabetes,” said HRSA Administrator Tom Engels. “Expanding affordable access to lifesaving medications like insulin and injectable epinephrine can significantly improve the health status of patients with chronic diseases, ultimately reducing or even eliminating health disparities that acutely impact underserved and minority communities nationwide.”

Read the release.