This week in Medicare updates—4/1/2020
CMS Announces Relief for Clinicians, Providers, Hospitals, and Facilities Participating in Quality Reporting Programs in Response to COVID-19
On March 22, CMS published a Press Release to announce it is granting exceptions from reporting requirements as well as extensions for clinicians and providers who participate in Medicare quality reporting programs. CMS is extending the Quality Payment Program (both MIPs and ACO tracks) to extend reporting deadlines for 2019 data from March 31, 2020, to April 30, 2020. MIPS eligible clinicians who are unable to report data by April 30 will qualify for an automatic extreme and uncontrollable circumstances policy and will receive neutral payment adjustments for 2021. Hospital quality programs have optional Q4 data submission as well as changes for 2020 data submission. There are also extensions and exemptions for post-acute care programs.
Prioritization of Survey Activities
On March 23, CMS published a Memorandum to state survey agency directors regarding the types of surveys that will be prioritized for the three-week period beginning on March 23, 2020. As long as state or federal surveyors are able to meet the personal protective equipment (PPE) expectations set by the CDC, they will be performing complaint/facility-reported incident surveys, targeted infection control surveys, and self-assessments. The memorandum provides more details about the elements of those three survey types as well as the types of surveys that will not be conducted over the three week period. The guidance in this memo supersedes that from the previous survey guidance issued on March 4.
CMS published a Fact Sheet and Press Release on the changes to survey activities, especially in light of the COVID-19 outbreak at the Kirkland Nursing Home in Washington, on the same date.
Effective date: Immediately. This policy should be communicated with all survey and certification staff, their managers, and the state/regional office training coordinators immediately.
COVID-19 Medicare Provider Enrollment Relief FAQs
On March 23, CMS published an FAQ on Medicare provider enrollment relief related to COVID-19. The FAQ addresses the section 1135 waiver, provider enrollment hotlines, the amount of time it will take to get temporary billing privileges approved, a telehealth question related to distant site practitioners, and more.
OIG Telehealth Policy Statement FAQ
On March 24, the OIG published an FAQ regarding questions it has received since issuing the March 17 policy statement on reducing or waiving cost-sharing amounts for telehealth services. The FAQ discusses what services the police statement applies to and whether it applies to hospitals when a physician/other practitioner who reassigned his or her right to the hospital for telehealth services.
ICD-10-CM Tabular List of Diseases and Injuries - April 1, 2020 Addenda
On March 25, the CDC published the Addenda to the ICD-10-CM Tabular List that will be effective April 1, 2020. This includes the addition of the U07.0 Vaping-related disorder code instructions and the U07.1 COVID-19 coding directions.
April 2020 Update of the Hospital Outpatient Prospective Payment System (OPPS)
On March 25, CMS published Medicare Claims Processing Transmittal 10013, which rescinds and replaces Transmittal 4544, dated March 6, to revise section I.B.3 to add new coronavirus CPT codes U0002 and 87635, and to add a new section I.B.4.f to revise a status indicator for Q5118 from E2 to status indicator K. The transmittal also updates table 3 and adds a new table 7 to attachment A. The original transmittal was issued regarding changes implemented in the April 2020 OPPS update. This includes several changes to proprietary laboratory analyses codes, new status indicators associated with the NCD for acupuncture and dry needling, implementation of the new coronavirus lab test HCPCS code (U0001), and more.
Effective date: April 1, 2020
Implementation date: April 6, 2020
Beneficiary Notice Delivery Guidance in Light of COVID-19
On March 26, CMS published a Special Edition MLN Connects containing three items related to COVID-19. One of those items contains guidance on how to deliver notices to beneficiaries in isolation. Hard copies may be dropped off by any hospital worker who can safely enter the room. Contact phone numbers should be included in case the beneficiary has questions. If hard copies cannot be dropped off, notices can be delivered by email if the beneficiary has email access in isolation.
CLIA Laboratory Guidance During COVID-19 Public Health Emergency
On March 26, CMS published a Memorandum to state survey agency directors regarding guidance for surveyors and laboratories during the COVID-19 public health emergency. The memo discusses remote review of pathology slides, temporary lab testing sites, expedited review of CLIA applications, proficiency testing during the public health emergency, and more.
Effective date: Immediately. This policy should be communicated with all survey and certification staff, their managers and the state/regional office training coordinators within 30 days of this memo.
Implementation of Additional Requirement to add HCPCS and CPT - HCPCS/CPT as Paired Items of Service for Prior Authorization and Medicare Claims Processing for Part A, Part B, DME, and Home Health and Hospice
On March 27, CMS published One-Time Notification Transmittal 10021, which rescinds and replaces Transmittal 2438, dated February 21, 2020, to remove the business requirements 11516.7 and to change the PA Program Indicator in the attachment Criteria Template. The original transmittal was issued regarding the implementation of claims processing requirements for prior authorization programs and Medicare claims processing to add HCPCS and CPT - HCPCS/CPT as paired items of service for future processing.
Effective date: July 1, 2020
Implementation date: July 6, 2020
Congress Passes CARES Act
On March 27, President Trump signed the Coronavirus Aid, Relief, and Economic Security (CARES) Act into law. This legislation contains a variety of provisions affecting healthcare providers and facilities, including multiple provisions to expand telehealth services as well as stimulus checks to aid providers affected by the pause in elective procedures. The law also includes provisions regarding Medicare advance payments, Medicare sequestration relief, delayed Medicaid disproportionate share hospital reductions, and more.