Monday Morning Rounds with CMS

ICYMI, here is recent communication from CMS.

News

Now Open: Virtual Group Election Period for the MIPS 2022 Performance Year
If you’re interested in forming a virtual group for the 2022 Merit-based Incentive Payment System (MIPS) performance year, the election period starts today. To form a virtual group, an election must be submitted to CMS via e-mail between October 1, 2021 and December 31, 2021 (11:59 p.m. ET).

NOTE: A virtual group must submit an election to CMS for each performance year that it intends to participate in MIPS as a virtual group (as required by statute). If your virtual group was approved for the 2021 MIPS performance year and intends to participate in MIPS as a virtual group for the 2022 MIPS performance year, your virtual group is still required to submit an election to CMS for the 2022 MIPS performance year between October 1, 2021 and December 31, 2021 (11:59 p.m. ET).

Administration Advances Key Protections Against Surprise Medical Bills, Giving Peace of Mind to Millions of Consumers Plagued by High Costs
The Biden-Harris Administration, through the Departments of Health and Human Services (HHS), Labor (DOL), Treasury (collectively, the Departments), and the Office of Personnel Management (OPM) issued an interim final rule with comment period to further implement the No Surprises Act – a consumer protection law that helps curb the practice of surprise medical billing.

Medicare Advantage Value-Based Insurance Design Model Calendar Year 2022 Model Participation
CMS is announcing the Calendar Year 2022 participants in the Medicare Advantage (MA) Value-Based Insurance Design (VBID) Model. There is a more than two-fold increase in the number of Model enrollees covered by participating MA plans in 2022 compared to 2021. Through the VBID Model, CMS is testing a broad array of MA health plan innovations designed to enhance the quality of care for Medicare beneficiaries – including those with low income, such as dually eligible beneficiaries and those qualifying for Low Income Subsidy (LIS) – as well as to reduce costs for enrollees and the overall Medicare program.

Flu & Pneumococcal Vaccines: Expanded SNF Enforcement Discretion for Certain Pharmacy Billing
Effective September 20, 2021, CMS exercised enforcement discretion for Skilled Nursing Facility (SNF) consolidated billing provisions related to flu and pneumococcal vaccines. This allows Medicare-enrolled immunizers, including pharmacies, to bill directly and get direct reimbursement from the Medicare program (including vaccine administration and product), whether these vaccines are administered at the same time (co-administered) with a COVID-19 vaccine or at different times. Visit the SNF: Enforcement Discretion Relating to Certain Pharmacy Billing webpage.

Learn More About AUR Reporting as an Option for Meeting the Public Health and Clinical Data Exchange Requirements
October 3, 2021, marks the start of the last continuous, 90-day period in 2021 for which eligible hospitals and critical access hospitals (CAHs) can report on the Promoting Interoperability Programs’ four required objectives and their associated measures.

CMS Updates 2020 MIPS Performance Feedback and 2022 MIPS Payment Adjustments
CMS released performance feedback for clinicians included in the Merit-based Incentive Payment System (MIPS) for the 2020 performance year (PY). Along with releasing performance feedback, we opened the targeted review period. A targeted review provides the opportunity for clinicians, groups, virtual groups or those participating in certain Alternative Payment Models (APMs) to request review of their MIPS payment adjustment factor(s), if they believe there is an error with their final score and associated MIPS payment adjustment.

CMS Will Pay for COVID-19 Booster Shots, Eligible Consumers Can Receive at No Cost
Following the FDA’s recent action that authorized a booster dose of the Pfizer COVID-19 vaccine for certain high-risk populations and a recommendation from the CDC, CMS will continue to provide coverage for this critical protection from the virus, including booster doses, without cost sharing. Beneficiaries with Medicare pay nothing for COVID-19 vaccines or their administration, and there is no applicable copayment, coinsurance or deductible. In addition, thanks to the American Rescue Plan Act of 2021 (ARP), nearly all Medicaid and CHIP beneficiaries must receive coverage of COVID-19 vaccines and their administration, without cost-sharing.

CMS Launches New Medicare.gov Tool to Compare Nursing Home Vaccination Rates
CMS is making it easier to check COVID-19 vaccination rates for nursing home staff and residents with a new feature on Medicare.gov. This announcement makes vaccination data available in a user-friendly format to help people make informed decisions when choosing a nursing home for themselves or a loved one. CMS and the CDC are also continuing to use this data to monitor vaccine uptake among residents and staff and to identify facilities that may need additional resources or assistance to respond to the pandemic.

QPP Website Will No Longer Support IE 11 Browser
Microsoft is ending support for the Internet Explorer (IE) 11 browser in June 2022. As a result, this browser won’t be up to date with the latest security updates. Due to these security concerns, as of October 13, 2021 users won’t be able to access the Quality Payment Program (QPP) website, qpp.cms.gov using the IE 11 browser.

Administration Awards $15 Million to 20 States for Mobile Crisis Intervention
CMS awarded $15 million in planning grants to 20 states to support expanding community-based mobile crisis intervention services for Medicaid beneficiaries. By connecting people who are experiencing a mental health or substance use disorder crisis to a behavioral health specialist or critical treatment, these services—which will be provided by funding from the American Rescue Plan (ARP)— and will be available 24 hours per day, every day of the year, can help save lives. Importantly, these services can also help to reduce the reliance on law enforcement when people are experiencing a behavioral health crisis and, in turn, may help to prevent the unnecessary incarceration of people with serious mental illness or substance use disorders.

Quality Payment Program

Quality Payment Program: 2021 Performance Period Merit-based Incentive Payment System (MIPS) Quality Measures Impacted by the Annual ICD-10 Coding Update
In the Calendar Year (CY) 2021 Quality Payment Program Final Rule (85 FR 84898 through 84900), CMS finalized the policy allowing for the review of quality measures for significant impacts due to International Classification of Diseases, Tenth Revision (ICD-10) coding changes during the performance period. Performance for these quality measures will be assessed based only on the first 9 months of the 12-month performance period. Additional information regarding this policy can be found in the 2021 MIPS Quality Measures Impacted by ICD-10 Updates located on the QPP Resource Library.

Reminder: 2021 APM Incentive Payment Details Available; Learn if Action Needed
CMS previously published 2021 Alternative Payment Model (APM) Incentive Payment details on the Quality Payment Program (QPP) website. To access this information, clinicians and surrogates can now log in to the QPP website using their HARP credentials. Eligible clinicians who were Qualifying APM Participants (QPs) based on their 2019 performance should have begun receiving their 2021 5% APM Incentive Payments earlier this summer. CMS has posted the 2021 Learning Resources for QP Status and APM Incentive Payment (ZIP) with more details.

Update: 2020 MIPS Performance Feedback, Final Score, and 2022 MIPS Payment Adjustment Information
CMS will be updating the Merit-based Incentive Payment System (MIPS) performance feedback and final scores for some clinicians for performance year 2020 and the associated MIPS payment adjustment information for payment year 2022. You can view your current MIPS performance feedback, final score, and payment adjustment on the Quality Payment Program website. Please note the information you see now may be changing.

Upcoming MIPS Important Dates and Deadlines

CMS would like to remind clinicians of important upcoming Merit-based Incentive Payment System (MIPS) dates and deadlines:

  • October 1 – 2022 virtual group election period opened. Solo practitioners and groups with 10 or fewer clinicians (including at least one MIPS eligible clinician) who want to participate in MIPS as a virtual group for the 2022 performance year must submit their election to CMS.
  • October 3 – The last day to begin data collection for a continuous 90-day performance period for the improvement activities and Promoting Interoperability performance categories.
    • Note: Most, but not all, improvement activities have a continuous 90-day performance period, but several improvement activities require completion of modules where there’s a year-long or alternate performance period. The performance period is 90 days unless otherwise stated in the activity description.
  • December 31 – 2021 Promoting Interoperability Hardship Exception and Extreme and Uncontrollable Circumstances (EUC) Applications close. Clinicians, groups, and virtual groups who believe they’re eligible for these exceptions may apply, and if approved, will qualify for a re-weighting of one or more MIPS performance categories. Alternative Payment Model (APM) Entities can also request reweighting of all performance categories through the EUC application. CMS will notify applicants via email whether their requests are approved or denied. If approved, the exception will also be added to the QPP Participation Status Tool but may not appear in the tool until the data submission period begins in 2022.
  • December 31 – 2022 virtual group election period closes.
  • January 3, 2022 – 2021 MIPS performance year data submission period begins.
  • March 31, 2022 – 2021 MIPS performance year data submission period closes.

CMS is Hiring!

Claims, Pricers & Codes

  • Health Care Code Sets: ICD-10 — Revised
    Read new information (PDF) in this Medicare Learning Network fact sheet:

    • Simple code explanations
    • HIPAA requirement
    • Resources to advance health equity and help eliminate health disparities
  • HCPCS Level II Application Submission: Launch of MEARISTM
    The Medicare Electronic Application Request Information System (MEARIS) is available for HCPCS Level II fourth quarter 2021 and first biannual 2022 application submissions. For more information, visit the HCPCS – General Information webpage.
  • HCPCS Level II Application Submission Deadlines
    CMS announced HCPCS Level II application submission deadlines:

    • First quarter and first biannual 2022 coding cycles — January 4, 2022
    • Second quarter 2022 coding cycle — April 1, 2022
  • Non-Drug & Non-Biological Items and Services: HCPCS Application Summaries & Coding Decisions
    Visit the HCPCS Level II Coding Decisions webpage for more information.
  • ICD-10-CM Diagnosis Code Files for FY 2022
    Visit the 2022 ICD-10-CM webpage for Fiscal Year (FY) 2022 diagnosis code information
  • ICD-10-CM Codes: FY 2022
    Fiscal year (FY) 2022 ICD-10-CM codes are available on the 2022 ICD-10-CM webpage. Use these codes for discharges and patient encounters on or after October 1, 2021, through September 30, 2022.
  • ICD-10-PCS Procedure Codes: FY 2022
    Fiscal year 2022 ICD-10-PCS procedure codes are available on the 2022 ICD-10 PCS webpage. Use these codes for discharges on or after October 1, 2021, through September 30, 2022.

Resources

Additional Resources Now Available in 2021 Quality Benchmarks Zip File – When you submit measures for the Merit-based Incentive Payment System (MIPS) quality performance category, each measure is assessed against its benchmark to determine how many points the measure earns. The 2021 MIPS Quality Benchmarks (ZIP) lists and explains the 2021 benchmarks used to assess performance in the quality performance category of MIPS. This file is available on the QPP Resource Library.

CMS COVID Provider ToolkitCMS released a set of toolkits for providers, states and insurers to help the health care system prepare to swiftly administer the vaccine. These resources are designed to increase the number of providers that can administer the vaccine and ensure adequate reimbursement for administering the vaccine in Medicare, while making it clear to private insurers and Medicaid programs their responsibility to cover the vaccine at no charge to beneficiaries. In addition, CMS is taking action to increase reimbursement for any new COVID treatments that are approved by the FDA.

CDC COVID-19 Vaccination Communication Toolkit – Medical centers, clinics, and clinicians can use or adapt these ready-made materials to build confidence about COVID-19 vaccination among your healthcare teams and other staff.

MLN Matters Articles

From CMS Innovation Center

The Centers for Medicare & Medicaid Services Innovation Center, (@CMSinnovates) also known as “the Innovation Center,” develops and tests new healthcare payment and service delivery models.