CMS Announces Relief for Clinicians, Providers, Hospitals and Facilities Participating in Quality Reporting Programs in Response to COVID-19

Today, the Centers for Medicare & Medicaid Services (CMS) announced unprecedented relief for the clinicians, providers, and facilities participating in Medicare quality reporting programs including the 1.2 million clinicians in the Quality Payment Program and on the front lines of America’s fight against the 2019 Novel Coronavirus (COVID-19).

Specifically, CMS announced it is granting exceptions from reporting requirements and extensions for clinicians and providers participating in Medicare quality reporting programs with respect to upcoming measure reporting and data submission for those programs.  The action comes as part of the Trump Administration’s response to 2019 Novel Coronavirus (COVID-19).

“In granting these exceptions and extensions, CMS is supporting clinicians fighting Coronavirus on the front lines,” said CMS Administrator Seema Verma. “The Trump Administration is cutting bureaucratic red tape so the healthcare delivery system can direct its time and resources toward caring for patients.”

Specifically, CMS is implementing additional extreme and uncontrollable circumstances policy exceptions and extensions for upcoming measure reporting and data submission deadlines for the following CMS programs:

Provider Programs2019 Data Submission2020 Data Submission
·      Quality Payment Program – Merit-based Incentive Payment System (MIPS)  Deadline extended from March 31, 2020 to April 30, 2020.   MIPS eligible clinicians who have not submitted any MIPS data by April 30, 2020 will qualify for the automatic extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year.CMS is evaluating options for providing relief around participation and data submission for 2020.
  ·      Medicare Shared Savings Program Accountable Care Organizations (ACOs)
Hospital Programs2019 Data Submission2020 Data Submission
·      Ambulatory Surgical Center Quality Reporting ProgramDeadlines for October 1, 2019 – December 31, 2019 (Q4) data submission optional.   If Q4 is submitted, it will be used to calculate the 2019 performance and payment (where appropriate). If data for Q4 is unable to be submitted, the 2019 performance will be calculated based on data from January 1, 2019 – September 30, 2019 (Q1-Q3) and available data.    CMS will not count data from January 1, 2020 through June 30, 2020 (Q1-Q2) for performance or payment programs. Data does not need to be submitted to CMS for this time period.   * For the Hospital-Acquired Condition Reduction Program and the Hospital Value-Based Purchasing Program, if data from January 1, 2020 – March 31, 2020 (Q1) is submitted, it will be used for scoring in the program (where appropriate).
·      CrownWeb National ESRD Patient Registry and Quality Measure Reporting System
·       End-Stage Renal Disease (ESRD) Quality Incentive Program
·       Hospital-Acquired Condition Reduction Program
·       Hospital Inpatient Quality Reporting Program
·       Hospital Outpatient Quality Reporting Program
·       Hospital Readmissions Reduction Program
·       Hospital Value-Based Purchasing Program
·       Inpatient Psychiatric Facility Quality Reporting Program
·       PPS-Exempt Cancer Hospital Quality Reporting Program
·       Promoting Interoperability Program for Eligible Hospitals and Critical Access Hospitals
Post-Acute Care (PAC) Programs2019 Data Submission2020 Data Submission
  ·       Home Health Quality Reporting Program  Deadlines for October 1, 2019 – December 31, 2019 (Q4) data submission optional.   If Q4 is submitted, it will be used to calculate the 2019 performance and payment (where appropriate).    Data from January 1, 2020 through June 30, 2020 (Q1-Q2) does not need to be submitted to CMS for purposes of complying with quality reporting program requirements.   * Home Health and Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey data from January 1, 2020 through September 30, 2020 (Q1-Q3) does not need to be submitted to CMS.   * For the Skilled Nursing Facility (SNF) Value-Based Purchasing Program, qualifying claims will be excluded from the claims-based SNF 30-Day All-Cause Readmission Measure (SNFRM; NQF #2510) calculation for Q1-Q2.  
  ·       Hospice Quality Reporting Program
  ·       Inpatient Rehabilitation Facility Quality Reporting Program
  ·       Long Term Care Hospital Quality Reporting Program
  ·       Skilled Nursing Facility Quality Reporting Program
  ·       Skilled Nursing Facility Value-Based Purchasing Program

For those programs with data submission deadlines in April and May 2020, submission of those data will be optional, based on the facility’s choice to report.  In addition, no data reflecting services provided January 1, 2020 through June 30, 2020 will be used in CMS’s calculations for the Medicare quality reporting and value-based purchasing programs. This is being done to reduce the data collection and reporting burden on providers responding to the COVID-19 pandemic. 

CMS recognizes that quality measure data collection and reporting for services furnished during this time period may not be reflective of their true level of performance on measures such as cost, readmissions and patient experience during this time of emergency and seeks to hold organizations harmless for not submitting data during this period. 

CMS will continue monitoring the developing COVID-19 situation and assess options to bring additional relief to clinicians, facilities, and their staff so they can focus on caring for patients.  This action, and earlier CMS actions in response to COVID-19, are part of the ongoing White House Task Force efforts. To keep up with the important work the Task Force is doing in response to COVID-19, please visit www.coronavirus.gov. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the Current Emergencies Website

AMA’s ROLE IN COVID-19 PANDEMIC

The following is a message from American Medical Association EVP/CEO James L. Madara, MD. 

The COVID-19 pandemic represents an enormous threat to public health and an extreme challenge to physicians. Now, more than ever, physicians need a powerful ally in patient care. The AMA’s COVID-19 response strategy, attached, provides a road map for our initiatives in an unprecedented pandemic scenario. The strategy frames the AMA’s response in three key areas:

  • Providing clear, evidence-based guidance from trusted resources, including JAMA Network, the CDC, WHO, state and local agencies and AMA subject matter experts.
  • Building an interface with physicians on the front line, allowing them to share their experience with other physicians, the government and key health agencies.
  • Removing obstacles to diagnosis and treatment through our Advocacy, CPT, PS2 and other initiatives.

We are acquiring many ideas and we filter them through the above three strategic channels (keeping in mind the overarching view of what it is the AMA does well). Since early January, we have closely monitored the global outbreak of COVID-19 and compiled up-to-the-moment information for physicians. Here are some examples of what we’ve done recently viewed through the lens of our COVID-19 response strategy:

  • Building an interface with physicians on the front lines
    • Speaking directly to power on behalf of physicians
    • Conversations and updates with our Federation partners and AMA Ambassadors
    • Learning from and sharing first-hand accounts of physicians on the front lines. Listen to JAMA Editor Howard Bauchner, MD interview Maurizio Cecconi, MD in Italy and NIAID’s Anthony Fauci, MD;  read how the Permanente Medical Group developed new approaches to preserve PPE. 
    • Listening to and answering questions from physicians on twitter, leveraging ambassadors to engage and spread the word, and will be conducting Twitter chats to answer physician questions and share experiences. 
    • Called on the Administration for $100 billion dollars to support front line health care personnel and providers.
  • Removing obstacles to diagnosis and treatment
  • AMA Head: Lack of protective gear for health care workers is ‘unacceptable’
  • AMA Calls on Administration to Use Every Lever to Address Protective Equipment Needs, Lack of Tests in COVID-19 Fight
  • Mobilizing a dramatic increase in the nation’s telemedicine capacity through its advocacy and publication of the Quick Guide to Telemedicine in Practice, a new resource to help physicians implement remote care.
  • Developed new CPT code for coronavirus.
  • Eased restrictions on the use of laboratory developed tests for COVID-19 testing to expand local access. 
  • Administration exercising flexibility in reducing regulatory burdens by allowing physicians to care for Medicare beneficiaries in States other than where they are licensed, waiving enrollment requirements and expediting enrollment, and waiving the requirement for Medicare patients for a 3-day hospitalization prior to covering skilled nursing facility care.  
  • Worked with HHS on the development of new recommendations for deferring non-urgent elective procedures that are consistent with recommendations of the American College of Surgeons. 

The AMA’s COVID-19 news and video coverage is promoted across the AMA website, email, Morning Rounds, all social platforms and Apple News. Since COVID-19 coverage began through March 18, nearly 390,000 users have consumed COVID-19 content from the AMA website, including nearly 17,000 clicks/referrals to JAMA and EdHub resources.

Resources

AMA Letters:

  • March 19  Letter to Congressional Leaders re: urgent steps to help preserve viability of physician practices due to the demands of COVID-19.
  • March 18  Letter to Seema Verma re: CPT code clarification in light of COVID-19 with remote physiologic monitoring and telephone evaluation and management.
  • March 16  Letter to Michael Pence re: Request for assistance with shortage of personal protective equipment for health care professionals.
  • March 13  Letter to Alex Azar re: Medicare assistance for solutions facing the nation with the COVID-19 outbreak.

Sign-On Letters:

Press releases to date:

March 20:

March 19:

March 18:

March 17:

March 13:

March 10:

March 5:AMA statement on Congress passing supplemental COVID-19 appropriations

The Last Word – December 2019

By Hujefa Vora

I want to close out this year talking about change.  How much have your practices changed in the past year?  How much have your lives changed over the past year?  You’ll notice that I use the terms practice and life interchangeably.  Unbeknownst to our patients, our clients, our friends, and sometimes even our own families, these terms are equivalents.  One cannot achieve the title of physician without accepting this fact.  Our work defines us as human beings.  There is no other way to make an accounting of all the time we spend caring for others while neglecting our personal responsibilities.  This year, I missed my daughter’s first gymnastics meet because I had a patient attempting to code in the hospital.  Life changes.  Practices change.  When the government rolls out new regulations governing how we practice medicine, it changes not only our interactions with our patients and their insurance companies, but also the relationships we have nurtured over the years.

So how has my practice changed?  I recall a time just 10 years ago when I could easily see 20 patients a day in my office.  Comfortably.  I remember being able to do my documentation while I sat in front of the patient.  Prescriptions were sent off with a click or two of my mouse.  Follow ups were scheduled and the patient was satisfied. I started my practice 13 years ago with the exact same electronic medical records system that I am using today.  That has not changed, though there have been many updates to the system over the years.  What has changed quite dramatically now is how I use this system.  Practice with the same system for more than a decade, and users build a higher level of proficiency and efficiency.  It would make sense that I would be faster with the system, that my proficiency would make it easier to navigate the windows and the electronic maze of my patient’s chart.  Changes over the years in the rules behind coding and documentation have not made us more efficient though.  Let me give you my most cumbersome example of change in my practice pattern brought on by changes in rules and regulations brought about Medicare.  I am an internist by trade, but the vast majority of my patients are diabetics, so I fancy myself a closet endocrinologist most days.  When I first started practicing, I routinely ordered glycosylated hemoglobin (a1C) levels to gauge the degree of control my patients had over their diabetes.  My staff would order the test for the patient to have drawn at a local lab.  We would get the results back and I would call the patient a week later, provided the patient went to get their blood work in the first place.  Based on the results of that test and the discussion with the patient, I would call in any medication changes.  Then, we would follow up with the patient in a month or two and see if the medication adjustment worked by rechecking the levels.  This worked for a few years, until Medicare and the insurance companies decided that a1C levels would only be paid for if they were drawn three months apart.  Patients would get angry at me and my staff when they started getting bills for the a1Cs I was ordering.  We were forced to move away from this really good method of tracking diabetic

Patients would get angry at me and my staff when they started getting bills for the a1Cs I was ordering.

control.  I started bringing my diabetics into the office every three or four months.  My supply salesman introduced me to a machine that we could use in the office to check a1C levels. The catch here was that regulations dictated that because I was not

running a certified lab, the insurance companies would not always pay for the a1Cs we drew in the office.  Thus, only some of my patients got everything done at the point of care.  It was easily noticeable with my patients that those who had their a1Cs checked at the time of visit had better overall long-term outcomes in relation to their diabetic care.  Medicare eventually took notice of the importance of measuring glycosylated hemoglobin levels and started asking us to track these levels more routinely.  With the advent of Medicare’s quality initiatives several years ago, tracking a1C levels became a key quality indicator for diabetes control.  It is only recently that they started paying for this test if it was done in the office.  Reporting of quality metrics has been the ultimate gamechanger.  As every insurance company begins to incorporate the reporting of these quality metrics, the process has become even more cumbersome.  I decided that the easiest way to tackle this issue was to measure all a1Cs in-house.  If the insurance company would not pay, then my practice would eat the cost, not pass it along to the patient.  Every company we have worked with on this particular metric has a different way that they want these values reported to them.  Medicare has codes for the different ranges of the a1C that have to be coded into the note at the time of care, so whether or not they paid for the test became irrelevant.  A patient with no reported glycosylated hemoglobin level was just as bad as an uncontrolled diabetic in terms of the scoring of the quality of care being provided by the physician.  Ultimately, a lower quality score means a significant drop in revenue.  Most insurance companies would not allow us to simply document the level in the chart.  Medicare would not allow an a1C to be reported without proper documentation that the test was done in-house.  We are now required to document the value of the test, followed by phrases stating that the test was “drawn, collected, and performed in office, in-house, today <today’s date>, at <time>.”

My patient volume has not increased substantially, but the amount of time required to see each patient has made it impossible to continue to do this on my own.

Understand that Medicare has primary care physicians tracking over 30 different quality metrics for every patient we see.  Also understand that what Medicare does in terms of regulations trickles down to every commercial insurance plan eventually.  So how has my practice changed?  I am a five-star rated doctor for Medicare.  That means that because I am truly obsessive-compulsive about most of these details and metrics, my staff and I keep track of all of these metrics for all of our patients at all of their visits all of the time.  First and foremost, we do our best to provide the ultimate in good service and care to our patients.  Then, we spend the rest of our time buffing and polishing the patients’ charts so that we can stay in business and continue to serve our patients.  A typical visit of 10 minutes of face-to-face time with the patient requires about 20 minutes of documentation, insurance processing, and quality reporting.  A simple follow-up visit takes a minimum of 30 minutes.  A new patient may have taken 30 minutes when I first started my practice, but we typically give an hour of my time for these visits now.  And I had to hire a second nurse practitioner to keep up with the flow of patients.  My patient volume has not increased substantially, but the amount of time required to see each patient has made it impossible to continue to do this on my own.

And so, the practice of medicine continues to change.  Our lives continue to change.  I hate to be a pessimist, but not much of the change feels positive right now.  The optimist in me says the next year will be better.  I just hope that I don’t miss too many more gymnastics meets.  No one twirls quite so beautifully, or awkwardly, as my little girl.  That too will change.  My name is Hujefa Vora, and this is the Last Word.


Follow our links below to learn more about TCMS!