Monday Morning Rounds with CMS

ICYMI, here is recent communication from CMS.

Events

Deadlines

Update: Participate in Field Testing of Cost Measures – Deadline Extended to March 25th
CMS and its contractor, Acumen, LLC, are conducting field testing of 5 episode-based cost measures. CMS has determined that the field testing period will be extended by 30 days and will now end on March 25, 2022. They greatly appreciate the comments that they have received to-date ahead of the initial February 25 deadline, and encourage stakeholders to continue to submit comments as close to the original deadline as possible.

CMS Reopens the MIPS Extreme and Uncontrollable Circumstances Application for the 2021 MIPS Performance Year in Response to COVID-19
CMS continues to offer flexibilities to provide relief to clinicians responding to the COVID-19 public health emergency. They applied the MIPS automatic extreme and uncontrollable circumstances policy to all individual MIPS eligible clinicians for the 2021 performance period. Now they have also reopened the MIPS EUC application for groups, virtual groups, and APM Entities through March 31, 2022, at 8 p.m. ET. (Because of the automatic EUC policy, you don’t need to submit an application for individual clinicians.) Please note that applications received between now and March 31, 2022, won’t override previously submitted data for groups and virtual groups. MIPS EUC applications citing COVID-19 as the triggering event can be submitted until Thursday, March 31, 2022, at 8 p.m. ET.

MIPS 2021 Data Submission Period is Now Open
CMS has opened the data submission period for Merit-based Incentive Payment System (MIPS) eligible clinicians who participated in the 2021 performance year of the Quality Payment Program (QPP). Data can be submitted and updated from now until 8:00 p.m. ET on March 31, 2022.

Submit Comments on Episode-Based Cost Measure Comprehensive Reevaluation Now through May 28, 2022
CMS and its contractor, Acumen, LLC, are gathering input on eight episode-based cost measures being considered for comprehensive reevaluation through a Call for Public Comment. The measures included in this Call for Public Comment are those that were added to the MIPS in performance year 2019. Stakeholders are invited to submit their feedback in response to the information and questions included in the document between now and May 28, 2022, at 11:59 p.m. ET.

News

CMS Redesigns Accountable Care Organization Model to Provide Better Care for People with Traditional Medicare
CMS announced a redesigned ACO model that better reflects the agency’s vision of creating a health system that achieves equitable outcomes through high quality, affordable, person-centered care. The ACO Realizing Equity, Access, and Community Health (REACH) Model, a redesign of the Global and Professional Direct Contracting Model, addresses stakeholder feedback, participant experience, and Administration priorities, including CMS’ commitment to advancing health equity.

Accountable Care Organization Realizing Equity, Access, and Community Health Model
CMS has redesigned the Global and Professional Direct Contracting Model Model to advance Administration priorities, including our commitment to advancing health equity, and in response to stakeholder feedback and participant experience. The CMS Innovation Center is releasing a Request for Applications to solicit a cohort of participants for the ACO Realizing Equity, Access, and Community Health Model. The GPDC model will be renamed the ACO REACH model to better align the model’s name with its purpose: to encourage health care providers to coordinate care to improve the care offered to people with Medicare – especially those from underserved communities, a priority of the Biden-Harris Administration.

Open Now: Submit Comments on Wave 5 Candidate Episode Groups Now through April 1, 2022
CMS and its contractor, Acumen, LLC, are gathering input on episode groups to consider for Wave 5 of MIPS cost measure development through a Call for Public Comment. Stakeholders are invited to submit their feedback in response to the information and questions included in the comment posting document through April 1, 2022. You may access the public comment materials on the CMS Currently Accepting Comments Page: Wave 5 Measure Development – Call for Public Comment; Preliminary Specifications of Wave 5 Candidate Episode Groups Workbook; To provide feedback, you may submit a response or upload a comment letter to the Wave 5 Measure Development Survey.

Quality Payment Program

2020 Quality Payment Program Performance Information Now Available on Care Compare
CMS added new QPP performance information for doctors, clinicians, groups, and ACOs to the Doctors and Clinicians section of Medicare Care Compare and in the Provider Data Catalog. CMS is required to report MIPS eligible clinicians’ final scores, MIPS eligible clinicians’ performances under each MIPS performance category, names of eligible clinicians in Advanced APMs and, to the extent feasible, the names and performance of such Advanced APMs. Performance information for doctors and clinicians is displayed using measure-level star ratings, percent performance scores, and checkmarks.

MIPS Flexibilities and Resources Available to Support Clinicians Responding to COVID-19
CMS continues to provide relief where possible to clinicians responding to the 2019 Coronavirus public health emergency. CMS is applying the Merit-based Incentive Payment System automatic extreme and uncontrollable circumstances policy to ALL individually eligible MIPS eligible clinicians for the 2021 performance year. The automatic EUC policy only applies to MIPS eligible clinicians who are eligible to participate in MIPS as individuals. The automatic EUC policy doesn’t apply to groups, virtual groups, or Alternative Payment Model Entities.

MIPS Value Pathways (MVPs) Ongoing Maintenance Process
As noted in the CY 2022 Physician Fee Schedule (PFS) final rule under the “Maintenance Process for MVPs” section (86 FR 65410), CMS is soliciting stakeholder recommendations for potential updates to the 7 established MVPs that were finalized for implementation beginning in the 2023 MIPS performance period/2025 MIPS payment year.

CMS Releases Preliminary 2020 Performance Year Quality Payment Program Results
CMS released an infographic to share preliminary participation data for the Quality Payment Program (QPP) in 2020. CMS is pleased to share that despite the ongoing challenges caused by the COVID-19 Public Health Emergency, clinicians still overwhelmingly engaged in QPP and submitted 2020 data.

QPP Participation Status Tool Now Includes Third Snapshot of 2021 Qualifying APM Participant and MIPS APMs Data
CMS updated its Quality Payment Program Participation Status Lookup Tool based on the third snapshot of data from Alternative Payment Model (APM) entities.

The third snapshot includes data from Medicare Part B claims with dates of service between January 1, 2021 and August 31, 2021. The tool includes 2021 Qualifying APM Participant (QP) and Merit-based Incentive Payment System (MIPS) APM participation status.

Promoting Interoperability

Medicare Promoting Interoperability Program 2022 Specification Sheets are now Available
CMS has released the specification sheets for the 2022 Medicare Promoting Interoperability Program for eligible hospitals and critical access hospitals (CAHs). The specification sheets provide a guide to the program’s measures. scoring details, and additional resources for participating eligible hospitals and CAHs.

The Deadline to Register and Attest for the CY 2021 Medicare Promoting Interoperability Program for Eligible Hospitals and Critical Access Hospitals is March 31, 2022
The deadline to register and attest for the calendar year (CY) 2021 EHR reporting year for CMS Medicare Promoting Interoperability Program is March 31, 2022 at 11:59 p.m. ET. Program participants from eligible hospitals and critical access hospitals (CAHs) are required to attest through CMS’s Hospital Quality Reporting system (previously, the QualityNet Secure Portal).

“Medicare and Medicaid Promoting Interoperability Programs” becomes “Medicare Promoting Interoperability Program for eligible hospitals and CAHs” after ending of Medicaid Promoting Interoperability Program
With the Medicaid Promoting Interoperability Program ending in program year 2021, CMS has changed the Medicare and Medicaid Promoting Interoperability Programs name to the Medicare Promoting Interoperability Program for eligible hospitals and CAHs.” Previously, information distributed under the Promoting Interoperability Programs listserv was for participants of either program. Moving forward, information distributed through this listserv will be only relevant for eligible hospitals and critical access hospitals participating in the Medicare Promoting Interoperability Program.

Administrative Simplification

Administrative Simplification Enforcement and Testing Tool
The Administrative Simplification Enforcement and Testing Tool (ASETT) is now available for use through the CMS ID Management (IDM) system.

You can use ASETT to file a complaint with the CMS National Standards Group (NSG) about alleged violations of the HIPAA Administrative Simplification requirements.

Compliance Review Program Findings
The CMS National Standards Group, on behalf of HHS, administers the Compliance Review Program. The program aims to promote compliance with HIPAA Administrative Simplification rules for electronic health care transactions. Since the program launched in April 2019, NSG has conducted 20 compliance reviews with a mix of clearinghouses and health plans.

To help covered entities prepare for compliance reviews, CMS has created a report with the most common violations of standards and operating rules from the reviews.

Find out more about the Compliance Review Program on the Administrative Simplification website.

CMS Innovation Center

CMS Innovation Center Global and Professional Direct Contracting (GPDC) Model Transition Announcement
As part of its renewed vision and strategy for driving health system transformation (PDF), the CMS Innovation Center is releasing a Request for Applications (RFA) (PDF) for the Accountable Care Organization (ACO) Realizing Equity, Access, and Community Health (REACH) Model.