Monday Morning Rounds with CMS

ICYMI, here is recent communication from CMS.



2023 Call for MIPS Promoting Interoperability Measures and Improvement Activities is Open
CMS encourages you to submit Promoting Interoperability measures and improvement activities for consideration for future years of the Merit-based Incentive Payment System (MIPS). The MIPS Annual Call for Measures and Activities process allows clinicians, professional associations and medical societies that represent clinicians, researchers, consumer groups, and others to identify and submit measures and activities.

2023 Call for MIPS Quality and Cost Measures is Open
CMS encourages you to submit quality and cost measures for consideration for future years of the Merit-based Incentive Payment System (MIPS). The MIPS Annual Call for Quality and Cost Measures process allows clinicians, professional associations, and medical societies that represent clinicians, researchers, consumer groups, and others to identify and submit measures. Currently, we’re accepting submissions for: Measures for the quality performance category; and Measures for the cost performance category. The 2023 Annual Call for Quality and Cost Measures is from January 30, 2023, to May 19, 2023. Interested parties can submit quality and cost measures for CMS consideration by completing the required fields and submitting applicable measure specifications and all supporting data files via the CMS Measures Under Consideration Entry/Review Information Tool (MERIT) by 8 p.m. ET on May 19, 2023.


CMS Releases New Information to Help Health Care Providers Prepare for the End of the COVID-19 Public Health Emergency on May 11
February 23: To help health care providers prepare for the end of the COVID-19 public health emergency (PHE) on May 11, 2023, CMS published updates about how the Medicare, Medicaid, Children’s Health Insurance Program (CHIP), and Marketplace programs will be affected at the conclusion of the PHE. CMS is taking these steps to keep health care providers informed as standards for compliance with CMS requirements are restored and other provider waivers will conclude as described in the updates. CMS’s approach aligns with the Biden-Harris Administration’s priority for an orderly, predictable transition leading into the close of the COVID-19 PHE.

February 21: To ensure that information about the ending of the COVID-19 PHE is accessible for people with Medicaid/CHIP coverage who have limited English proficiency or disabilities, CMS released information and resources to states about current language access requirements.

CMS Seeks Participants for the Bundled Payments for Care Improvement Advanced Model
February 21: CMS seeks applications from Medicare-enrolled providers, suppliers and Medicare accountable care organizations (ACOs) for the Bundled Payments for Care Improvement (BPCI) Advanced Model Year 7, which will begin January 1, 2024. Under the BPCI Advanced Model, participating entities ensure that the patient’s entire health care team – including the providers from all health care settings – communicate and collaborate on the quality and total cost of the patient’s care. CMS released a request for applications, which are due May 31, 2023, and opened the portal for interested organization to apply. CMS anticipates selecting the new participants in December 2023.

CMS Analysis Provides Insight into Skilled Nursing Facility 3-Day Waiver Use in ACOs
February 17: A new CMS analysis describes trends in use and outcomes associated with waiving the 3-day (two nights) stay requirement at an acute care hospital before discharge to a skilled nursing facility (SNF). The 3-day waiver for certain accountable care organizations (ACOs) allows providers to admit patients to certain SNFs directly from the community or after only one to two days in a hospital. The analysis finds shorter SNF lengths of stay and higher rates of discharge-to-home for waiver stays as well as lower or similar rates of adverse outcomes relative to non-waiver stays.

Health Affairs Publishes CMS Analysis that Shows Substantial Progress of Hospital Price Transparency Practices
February 14: CMS is making sure hospitals are moving in the right direction to provide consumers and stakeholder with required information on hospital charges. In a recent Health Affairs article called, “Hospital Price Transparency: Progress and Commitment to Achieving its Potential,” CMS outlines a new assessment of how hospitals have put price transparency requirements, that became effective on January 1, 2021, into practice and agency efforts to improve compliance.

Now Available: Updated 2023 CMS QRDA I Implementation Guide (IG), Schematron, and Sample Files for Hospital Quality Reporting
CMS has published an update to the 2023 CMS Quality Reporting Document Architecture (QRDA) Category I Implementation Guide (IG), Schematron, and Sample Files for Hospital Quality Reporting. The 2023 CMS QRDA I IG outlines requirements for eligible hospitals and critical access hospitals (CAHs) to report electronic clinical quality measures (eCQMs) for the calendar year 2023 reporting period.

CMS Issues Final Rule to Protect Medicare, Strengthen Medicare Advantage, and Hold Insurers Accountable
CMS finalized the policies for the Medicare Advantage (MA) Risk Adjustment Data Validation (RADV) program, which is CMS’s primary audit and oversight tool of MA program payments. Under this program, CMS identifies improper risk adjustment payments made to Medicare Advantage Organizations (MAOs) in instances where medical diagnoses submitted for payment were not supported in the beneficiary’s medical record. The commonsense policies finalized in the RADV final rule (CMS-4185-F) will help CMS ensure that people with Medicare are able to access the benefits and services they need, including in Medicare Advantage, while responsibly protecting the fiscal sustainability of Medicare and aligning CMS’s oversight of the Traditional Medicare and MA programs.

Rural Emergency Hospitals’ Guidance Released for Newest Medicare Provider Type
January 26, 2023: CMS released guidance for the newest Medicare provider type, Rural Emergency Hospitals (REH), outlining requirements on delivery of care, the conversion process for eligible facilities, survey guidelines, and the Conditions of Participation that facilities must meet to participate in the Medicare program. This new provider type was established to address the growing concern over closures of rural hospitals. The REH designation, established by the Consolidated Appropriations Act, 2021, provides an opportunity for Critical Access Hospitals and certain rural hospitals to continue to provide essential services to their communities.

CMS Released 2022 Accomplishments and Spotlights Key Advances in Health Care
January 26, 2023: CMS highlights key 2022 Accomplishments detailing the agency’s focus on continuous operational improvement and setting the benchmark for health-system transformation. CMS has made tremendous progress on its six strategic pillars: advancing health equity, expanding access, engaging partners, driving innovation, protecting programs, and fostering excellence, as well as the 13 cross-cutting initiatives driving results across the agency.

CMS Acts to Lower Prescription Drug Costs Under the Inflation Reduction Act (IRA)
January 23, 2023: CMS issued a Medicaid Drug Rebate Program manufacturers’ release providing drug manufacturers with technical information on the impact of the Inflation Reduction Act and other statutory changes on the calculation of Medicaid rebate reporting metrics.

January 23, 2023: CMS began to propose its data collection processes essential to carrying out the first year of the Medicare Drug Negotiation Program by posting a 60-day Federal Register Notice. CMS will gather information necessary to identify which drugs qualify for the small biotech manufacturer exemption for the early years of the Negotiation Program.

CMS has a number of resources available to help people with Medicare understand the reduced drug costs made possible under the Inflation Reduction Act, including a fact sheet and frequently asked questions about the updated Medicare cost sharing for insulin.

CMS Announces Increase in 2023 in Organizations and Beneficiaries Benefiting from Coordinated Care in Accountable Care Relationships
CMS announced that three innovative accountable care initiatives will grow and provide higher quality care to more than 13.2 million people with Medicare in 2023. More than 700,000 health care providers and organizations will participate in at least one of the three initiatives – the Medicare Shared Savings Program and two CMS Innovation Center accountable care model tests. This growth furthers achieving the CMS’ goal of having all people with Traditional Medicare in an accountable care relationship with their health care provider by 2030.

Quality Payment Program

Update: The Advanced Alternative Payment Model (APM) Incentive Payment is Extended for One Additional Year
In December 2022, Congress enacted provisions of the Advanced APM Consolidated Appropriations Act, 2023 that extended the availability of an APM Incentive Payment, allowing eligible clinicians who are Qualifying APM Participants (QPs) for the 2023 QP Performance Period to receive a 3.5% APM Incentive Payment in the 2025 payment year. Without this, there would have been a one-year gap with no statutory incentives for Advanced APM participation for payment year 2025. For the 2023 QP Performance Period and the associated 2025 payment year, the APM Incentive Payment will decrease from 5.0% to 3.5% of the QP’s estimated aggregate payments for covered professional services in the performance year. Additionally, the QP payment amount and patient count thresholds for participation in Advanced APMs will remain frozen at 50% and 35%, respectively, for performance period 2023 (payment year 2025) at the same levels that were in effect for performance period 2022.

Administrative Simplification

CMS Innovation Center