Monday Morning Rounds with CMS

ICYMI, here is recent communication from CMS.


CMS announced flexibilities being provided to ensure health care access continues for residents in Louisiana and Mississippi impacted by Hurricane Ida. On August 30, HHS Secretary Xavier Becerra declared Public Health Emergencies (PHEs) for Louisiana and Mississippi. With these PHEs in effect CMS is also notifying Louisiana and Mississippi of the resources and waivers being made available to ensure hospitals and other facilities can continue to operate and provide access to care to those impacted by Hurricane Ida. Many of these waivers were already in place as a result of the ongoing COVID-19 PHE.

As part of its implementation of the American Rescue Plan Act of 2021 (ARP), the Biden-Harris Administration is issuing guidance that provides essential information to states as they navigate the options available to advance COVID-19 vaccination and testing, and the Medicaid program’s broader aim of providing much-needed health coverage for millions of eligible individuals. To help states support families and communities and to continue to address health disparities, CMS will provide guidance to states about additional ARP funding for states to promote the importance of COVID-19 vaccination for eligible children and adults enrolled in Medicaid.

In 2021, CMS finalized changes to the Medicare Promoting Interoperability Program to continue the advancement of certified electronic health record technology (CEHRT) utilization, focusing on improving interoperability and health information exchange, including patient access to their health information. As a reminder, view detailed requirements for the 2021 Medicare Promoting Interoperability Program to ensure program participants continue to have a successful reporting period.

CMS developed and published the 2022 electronic clinical quality measure (eCQM) flows to the eCQI Resource Center. The eCQM flows supplement eCQM specifications for the 2022 reporting period for Eligible Hospitals/Critical Access Hospitals, and the 2022 performance period for Eligible Professionals/Eligible Clinicians.

In late August, CMS issued a Special Edition Comparative Billing Report (CBR) on the impact of the Public Health Emergency (PHE) on Part B claims for telehealth. Use the data-driven report to compare your billing practices during the PHE with those of your peers in your state and across the nation. CBRs aren’t publicly available. Look for an email from to access your report. Update your email address in the Provider Enrollment, Chain, and Ownership System to ensure delivery.

As part of the Biden-Harris Administration’s ongoing commitment to increasing access to vaccinations and improving health equity, CMS is expanding opportunities for people to receive COVID-19 vaccinations in their home. To ensure Medicare beneficiaries who have difficulty leaving their homes or are otherwise hard-to-reach can receive the vaccination, health care providers can now receive additional payments for administering vaccines to multiple residents in one home setting or communal setting of a home.

The FDA amended the emergency use authorizations (EUAs) for both the Pfizer BioNTech COVID-19 vaccine and the Moderna COVID-19 vaccine to allow for an additional dose in certain immunocompromised people. Effective August 12, 2021, CMS will pay to administer additional doses of COVID-19 vaccines consistent with the FDA EUAs, using CPT code 0003A for the Pfizer vaccine and CPT code 0013A for the Moderna vaccine. They will pay the same amount to administer this additional dose as we did for other doses of the COVID-19 vaccine (approximately $40 each).

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.

Deadlines & Important Dates

Reminder: Submit Comments on Policy Changes for Quality Payment Program in 2022 Physician Fee Schedule Proposed Rule
CMS issued its proposed policies for the 2022 performance year of the Quality Payment Program (QPP) via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rule Making (NPRM). The deadline to submit comments on the proposed rule is September 13, 2021.

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.
  • Average Sales Price Files: July 2021
    CMS posted the July 2021 Average Sales Price (ASP) and Not Otherwise Classified (NOC) pricing files and crosswalks on the 2021 ASP Drug Pricing Files webpage.


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.

Announced: Next Generation Accountable Care Organization (NGACO) Model Beneficiary and Provider RIF files now available on ResDAC and CCW
CMS announced the availability of new Research Identifiable Files (RIFs) that contain data from the Next Generation ACO (NGACO) Model for Performance Years 1-3. Two files are available for each payment year. The first file, the NGACO Beneficiary RIF, contains enrollment data for beneficiaries in the NGACO Model. A second file, the NGACO Provider RIF, contains identifying information about the providers participating in the NGACO Model.

Announced: Vermont All-Payer ACO Model
The Vermont All-Payer Accountable Care Organization (ACO) Model is CMS’s new test of an alternative payment model in which the most significant payers throughout the entire state – Medicare, Medicaid, and commercial health care payers – incentivize health care value and quality, with a focus on health outcomes, under the same payment structure for the majority of providers throughout the state’s care delivery system and transform health care for the entire state and its population.

Announced: Pennsylvania Rural Health Model
The Pennsylvania Rural Health Model seeks to test whether care delivery transformation in conjunction with hospital global budgets increase rural Pennsylvanians’ access to high-quality care and improve their health, while also reducing the growth of hospital expenditures across payers, including Medicare, and improving the financial viability of rural Pennsylvania hospitals to improve health outcomes of and maintain continued access to care for Pennsylvania’s rural residents.

Announced: Most Favored Nation Model
The Most Favored Nation (MFN) Model tests an innovative way to lower prescription drug costs by paying no more for high-cost Medicare Part B drugs and biologicals (hereinafter called drugs) than the lowest price that drug manufacturers receive in other similar countries. The MFN Model tests paying comparable amounts to the lowest price, adjusted for purchasing power, paid by any country in the Organisation for Economic Co-operation and Development (OECD) that has a Gross Domestic Product (GDP) per capita that is at least 60 percent of the U.S. GDP per capita. The model also tests a single add-on payment per dose and waives beneficiary cost sharing for this payment. The model will operate for seven years, from January 1, 2021, to December 31, 2027.

Announced: Part D Enhanced Medication Therapy Management Model
The Part D Enhanced Medication Therapy Management (MTM) model tests whether providing Part D sponsors with additional payment incentives and regulatory flexibilities promotes enhancements in the MTM program, leading to improved therapeutic outcomes, while reducing net Medicare expenditures. The model is an opportunity for stand-alone basic Part D plans to right-size their investments in MTM services, identify and implement innovative strategies to optimize medication use, improve care coordination, and strengthen health care system linkages.