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CMS

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.

Message from the National Council for Mental Wellbeing:

Proposed updates to the 2023 Physician Fee Schedule would expand access to mental health and substance use services and allow some providers more flexibility in treating Medicare enrollees. Reserve a spot today to join the National Council for Mental Wellbeing for a special webinar discussing the “incident to” billing provisions and what they mean for providers.

Register Now

Title: ‘Incident To’ Provisions of the Proposed 2023 Physician Fee Schedule
Time: August 16, 2022, at 12:00 pm ET

  • The Centers for Medicare and Medicaid Services (CMS) is proposing updates to the 2023 Physician Fee Schedule that would create an exception to the direct supervision requirement of “incident to” billing to allow for general supervision, which would allow certain mental health providers to be reimbursed without the physician or non-physician practitioners on-site requirement.
  • Medicare’s Physician Fee Schedule, updated yearly, contains a comprehensive listing of the maximum fees physicians and other providers may be reimbursed under fee-for-service in Medicare.

In this webinar, participants will be provided:

  • Overview of “incident to” billing in Medicare;
  • Summary of the “incident to” proposed rule changes for 2023;
  • Analysis of the impact and implications to providers;
  • Context for the applicability to dual eligible individuals; and
  • Dedicated Q&A period.

Questions? Contact us!

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2023 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule that was published in today’s Federal Register. Some of the key provisions contained in the final rule are provided below:

Final FY 2023 Payment Updates
CMS estimates overall payments to IRFs will increase by 3.2 percent compared to FY 2022 levels (higher than the 2 percent estimated in the proposed rule). This update is the result of a 4.2 percent update to the IRF market basket reduced by a 0.3 percent productivity adjustment, which is required by law. As a result of this market basket increase and a few small budget neutrality adjustments, the standard payment conversion factor will increase from $17,240 to $17,878. ‎CMS is also adjusting the outlier threshold, which it says will reduce overall payments by 0.6 percent. CMS says the 3.2 percent overall increase will result in $275 million in increased payments to IRFs compared to 2022.

Proposed Expansion of IRF Transfer Policy to Include Home Health Services
CMS issued a Request for Information (RFI) in the proposed rule regarding the potential expansion of the current IRF transfer payment policy to include home health services. For background, IRFs receive a reduced case mix group (CMG) payment rate under the IRF transfer policy when the patient’s discharge occurs earlier than the average length of stay (for that respective CMG and tier) and the patient is discharged to a certain setting (an IRF, acute-care hospital, LTCH, nursing home that takes Medicare and Medicaid payment). The policy currently does not apply to home health.

The RFI in this year’s rule followed a December 2021 Office of Inspector General (OIG) report finding that Medicare could have saved over $993 million had the IRF transfer policy been expanded to include home health services (based on 2017 and 2018 data). The OIG therefore recommends that CMS explore ways to capture early discharges to home health care in the current policy, which CMS referenced in the proposed rule. Following a review of concern cited in stakeholder comments, CMS is not moving forward with any changes to the transfer policy at this time.

IRF Quality Reporting Program Changes & Requests for Information All-Payer IRF-PAI Reporting Proposal
CMS proposed to require collection of the IRF-PAI for all IRF patients, including those without Medicare, beginning with the FY 2025 IRF QRP (with data collection to begin on October 1, 2023). Currently the IRF-PAI is only required to be collected for Medicare Part A (fee-for-service) and Part C (Medicare Advantage) beneficiaries. In response to comments, CMS opted to finalize the proposal but with a revised implementation date. IRFs will now be required to collect IRF-PAIs on all patients, regardless of payer, for the FY 2026 IRF QRP (data collection to begin on October 1, 2024).

RFI on Future QRP Measure Expansions
CMS had issued a Request for Information (RFI) related to measures/concepts for use in the QRP in future years in the proposed rule. The agency specifically requested information on a cross-setting function measure that would include self-care and mobility items, and development of a patient-level COVID-19 vaccination measure. CMS referenced several of AMRPA’s comments, including concerns that IRF stays are typically not long enough to adequately capture COVID-19 vaccination for patients. CMS did not provide a response to comments but affirmed the agency would use the stakeholder feedback to inform future rulemaking.

ODP Announcement 22-085 announces clarification for Supports Coordination Organizations (SCO) on resuming Waiver and Targeted Support Management (TSM) Supports Coordination (SC) in-person monitoring. Many adjustments have been made to the Office of Developmental Programs (ODP) policy and operations during the COVID-19 pandemic. Appendix K allowed for SC services to be provided remotely during the pandemic. ODP planned to replace the Appendix K guidance with new requirements detailed in the Intellectual Disability and Autism (ID/A) Waiver renewals and the Adult Autism Waiver (AAW) amendment effective July 1, 2022, to allow for some SC individual monitoring to continue to be completed remotely.

Both the ID/A Waiver renewals and the AAW amendment are pending approval with the Centers for Medicare and Medicaid (CMS). Therefore, ODP is issuing guidance to clarify the expected requirements of individual monitorings performed by SCs. This announcement outlines the updated requirements for SC in-person and remote monitoring and obsoletes that section of Appendix K.

ODP expects SCOs that were unable to meet the June 30 deadline for completing the in-person monitoring for at-risk individuals to continue to follow their plan and communicate with the ODP regional office to ensure that all the priority individuals are seen in-person.

This announcement outlines requirements for SCOs to implement no later than October 1. For additional questions, please contact your appropriate ODP regional office.

The Centers for Medicare & Medicaid Services (CMS) released a State Medicaid Director Letter (SMDL 22-003) providing guidance for the first-ever Home and Community-Based Services (HCBS) Quality Measure Set, the first of two planned guidance documents from CMS.

The HCBS Quality Measure Set is included in the SMDL, starting on page 14. The list of measures includes the NQF number (if applicable), measure steward, and data collection method, as well as information on whether each measure addresses section 1915(c) waiver assurances and/or can be used to assess access, LTSS rebalancing, and/or community integration and HCBS settings requirements.

Most of the measures are derived from consumer surveys; CMS gives states the flexibility to select measures from the consumer survey of their choice from the following validated tools: NCI®-IDD, NCI-AD™, HCBS CAHPS®, and POM®.

Visit here for more information.

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On July 13, 2022, the Centers for Medicare and Medicaid Services’ (CMS) Medicare Administrative Contractors (MACs) distributed notifications to inpatient rehabilitation facilities (IRFs) that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for calendar year (CY) 2021, which will affect their FY 2023 Annual Payment Update (APU). Non-compliance notifications were placed into facilities’ “Certification and Survey Provider Enhance Reports” (CASPER) folders in the Quality Improvement and Evaluation System (QIES) for hospice and skilled nursing facilities (SNFs), and into facilities’ “My Reports” folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs and long-term care hospitals (LTCHs). If a facility received a letter of non-compliance, it may submit a request for reconsideration to CMS via email. The submission deadline is 11:59 pm on August 11, 2022. View the full details and instructions for submission here.

On July 7, 2022, the Centers for Medicare and Medicaid Services (CMS) released the proposed Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2023. In this proposed rule, CMS is proposing an approximately 4 percent reduction to the base payment factor for all services for 2023. The specific level of adjustment providers may see will depend on changes CMS finalizes to other factors. CMS is also proposing to expand the list of codes that can be provided via telehealth through 2023 to include some therapy codes. Modifications to the Quality Payment Program (QPP), which includes the Merit-Based Incentive Payment System (MIPS), to allow for additional pathways for participation for certain specialties is also being proposed. The proposed rule will appear in the July 29 Federal Register.

The Centers for Medicare & Medicaid Services (CMS) has approved the Office of Long-Term Living’s (OLTL) Community HealthChoices (CHC) Waiver amendment that transfers oversight of Financial Management Services (FMS) from an OLTL-held contract to an administrative function of the CHC-MCOs and revises waiver performance measure AA-5. The amendment became effective on July 1, 2022.

The current approved CHC 1915(c) Waiver document with the FMS amendment can be viewed here. The link can be found under the heading “Community HealthChoices 1915(b) Managed Care and 1915(c) Home and Community-Based Waivers.”

Questions about the CHC Waiver amendment should be sent via email.

ODP Announcement 22-076 serves to announce that the Consolidated, Community Living, and Person/Family Directed Support (P/FDS) Waiver renewals, collectively known as the Intellectual Disability/Autism (ID/A) waivers, will not be effective on July 1, 2022, as requested.

This extension does not apply to the Adult Autism Waiver (AAW). The currently-approved AAW was most recently amended on April 1, 2022.

Discussions between the Office of Developmental Programs (ODP) and the Centers for Medicare & Medicaid Services (CMS) have been occurring since the submission of the waiver renewals. During recent discussions, it has become clear that the process to renew the waivers will not be complete by July 1. ODP requested a 90-day extension of the currently-approved waivers on June 27, 2022, since the Consolidated and Person/Family Directed Support waivers expire on June 30, 2022. CMS granted the extension request on June 27, 2022.

Until CMS approves the ID/A waiver renewals, the waiver amendments approved with an effective date of June 1, 2022, remain in effect. They can be found on the Department of Human Services website at the following links:

The ID/A waiver renewals submitted to CMS on April 1, 2022, are also available.

Additional changes will be made to the waiver renewals as a result of ongoing discussions with CMS. ODP will inform all stakeholders when the waiver renewals have been approved. The final approved versions of the waivers will be made available online at that time.

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The Centers for Medicare and Medicaid Services (CMS) recently issued updates associated with the inpatient rehabilitation facility (IRF) provider preview reports and the IRF Patient Assessment Instrument (PAI).

CMS has released the updated IRF Provider Preview Reports, which contain provider performance scores for quality measures and contain IRF-PAI data submitted by IRFs from Quarter 1 (Q1) 2021 through Quarter 4 (Q4) 2021, as well as CDC Clostridium Difficile (CDI) and Catheter-Associated Urinary Tract Infections (CAUTI) measures from Quarter 4 (Q4) 2020 through Quarter 3 (Q3) 2021, and Q4 2018 through Q1 2019 of the Healthcare Personnel (HCP) Influenza measure. The new HCP COVID-19 Vaccination Coverage measure will also be publicly reported on Care Compare in the September 2022 release and will reflect Q4 2021 data. Unlike prior September Care Compare refreshes, CMS will not be preforming the annual update to IRF claims-based measures, due to CMS only resuming the reporting of claims-based measures during the June 2022 refresh.

Providers have until July 15, 2022, to review their performance data. Providers can request CMS review their data during the preview period if they believe the scores are inaccurate. The final reports will be published on Care Compare and Provider Data Catalog during the September 2022 refresh of the website. Additional information is on the CMS IRF Quality Reporting Program (QRP) public reporting website.

CMS also published the IRF-PAI Quarterly Questions & Answers (Q&A) document that provides clarification to existing guidelines.