Monday Morning Rounds with CMS

ICYMI, here is recent communication from CMS.


CMS Takes Decisive Steps to Reduce Health Care Disparities Among Patients with Chronic Kidney Disease and End-Stage Renal Disease
CMS is taking action to close health equity gaps by providing Medicare patients living with End-Stage Renal Disease with greater access to care. Through the ESRD Prospective Payment System annual rulemaking, CMS is making changes to the ESRD Quality Incentive Program (QIP) and the ESRD Treatment Choices Model, and updating ESRD PPS payment rates. The changes to the ETC Model policies aim to encourage dialysis facilities and health care providers to decrease disparities in rates of home dialysis and kidney transplants among ESRD patients with lower socioeconomic status, making the model one of the agency’s first CMS Innovation Center models to directly address health equity.

CMS Extends Medicaid Postpartum Coverage in New Jersey for Over 8,000 People
CMS announced that an estimated 8,700 postpartum New Jerseyans will be guaranteed to maintain their Medicaid coverage for 12 months after the end of the pregnancy. This important step will help New Jersey to provide pregnancy-related care with the goal of preventing unnecessary postpartum-related illness and death. Today’s announcement is part of the Biden-Harris Administration’s efforts to address the nation’s crisis in pregnancy-related deaths and to improve the health outcomes among underserved communities through access to critical care.

CMS Issues Guidance to States on Required Medicaid and CHIP Coverage for COVID-19-Related Treatment
CMS issued guidance to states about the statutory requirement for states to cover COVID-19-related treatment without cost-sharing in Medicaid and CHIP for many seniors, low-income adults, pregnant women, children, and people with disabilities who receive health coverage through these programs. This life-saving health care coverage, supported through the American Rescue Plan, includes care for conditions that could complicate the treatment of COVID-19 in patients who are presumed positive for the virus or have been diagnosed with COVID-19.

CMS Launches Webpage to Share Innovative State Actions to Expand Medicaid Home and Community-based Services
CMS launched a new “one-stop shop” for state Medicaid agencies and stakeholders on to advance transparency and innovation for home and community-based services. Home and community-based services allow people enrolled in Medicaid to receive services and supports in a preferred setting outside of an institution, such as in their own home. Through this new webpage, state Medicaid agencies and stakeholders can access information about states’ plans to enhance, expand, and strengthen home and community-based services across the country using new Medicaid funding made available by the American Rescue Plan Act of 2021.

Medicare Promoting Interoperability Program Participants Can Apply for Payment Adjustment Reconsideration by December 3, 2021
The American Recovery and Reinvestment Act of 2009 requires critical access hospitals and eligible hospitals participating in the Medicare Promoting Interoperability Program to successfully demonstrate meaningful use of certified EHR technology during the applicable reporting period to avoid a downward payment adjustment for a CAH or EH applicable payment year. CAHs who are not meaningful users will receive a 100% instead of a 101% reimbursement of reasonable costs for their 2020 cost reports.

CMS Releases 2022 Medicare Advantage and Part D Star Ratings to Help Medicare Beneficiaries Compare Plans
CMS released the 2022 Star Ratings for Medicare Advantage (Medicare Part C) and Medicare Part D prescription drug plans to help people with Medicare compare plans ahead of Medicare Open Enrollment, which kicked off on October 15. Plans are rated on a one-to-five scale, with one star representing poor performance and five stars representing excellent performance. Star Ratings are released annually and reflect the experiences of people enrolled in Medicare Advantage and Part D prescription drug plans. The Star Ratings system supports CMS’s efforts to empower people to make health care decisions that are best for them.

Now Open: Virtual Group Election Period for the MIPS 2022 Performance Year
If you’re interested in forming a virtual group for the 2022 Merit-based Incentive Payment System (MIPS) performance year, the election period starts today. To form a virtual group, an election must be submitted to CMS via e-mail between October 1, 2021 and December 31, 2021 (11:59 p.m. ET).

NOTE: A virtual group must submit an election to CMS for each performance year that it intends to participate in MIPS as a virtual group (as required by statute). If your virtual group was approved for the 2021 MIPS performance year and intends to participate in MIPS as a virtual group for the 2022 MIPS performance year, your virtual group is still required to submit an election to CMS for the 2022 MIPS performance year between October 1, 2021 and December 31, 2021 (11:59 p.m. ET).

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.

Upcoming MIPS Important Dates and Deadlines

CMS would like to remind clinicians of important upcoming Merit-based Incentive Payment System (MIPS) dates and deadlines:

  • December 31 – 2021 Promoting Interoperability Hardship Exception and Extreme and Uncontrollable Circumstances (EUC) Applications close. Clinicians, groups, and virtual groups who believe they’re eligible for these exceptions may apply, and if approved, will qualify for a re-weighting of one or more MIPS performance categories. Alternative Payment Model (APM) Entities can also request reweighting of all performance categories through the EUC application. CMS will notify applicants via email whether their requests are approved or denied. If approved, the exception will also be added to the QPP Participation Status Tool but may not appear in the tool until the data submission period begins in 2022.
  • December 31 – 2022 virtual group election period closes.
  • January 3, 2022 – 2021 MIPS performance year data submission period begins.
  • March 31, 2022 – 2021 MIPS performance year data submission period closes.

Claims, Pricers & Codes

  • LTCH: New Web Pricer Released
    CMS released the fiscal years 2020 and 2021 Long-Term Care Hospital (LTCH) Web Pricer. For the best experience, access the Web Pricer through Google Chrome. You may also use Microsoft Edge or Mozilla Firefox, but not Microsoft Internet Explorer. Email your feedback on the LTCH Web Pricer to using the subject line “LTCH Web Pricer.”
  • 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.


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.

Maryland Total Cost of Care (MD TCOC) Model
In its first two years, the MD TCOC Model has engaged a wide range of providers to begin transforming care throughout the state. The model has continued the hospital global budgets that incentivize reductions in avoidable acute care while extending incentives and supports beyond the hospital to include post-acute providers, primary care, and community organizations. Future evaluations will assess whether care transformation continues, expands in reach, and succeeds in reducing Medicare total cost of care while improving quality of care and population health for all Marylanders.

Vermont All-payer Accountable Care Organization Model (VTAPM)
While the VTAPM failed to achieve its all-payer and Medicare scale target goals, in its first two performance years, the Model achieved statistically significant Medicare gross spending reductions at both the Accountable Care Organization (ACO) and state levels, as well as Medicare net spending reductions at the state level. There were declines in acute care stays (at the ACO and state levels) and in 30-day readmissions at the state level. These decreases in utilization and spending may reflect rising spending in the comparison groups and relatively flat spending in the VTAPM groups that began in the baseline period and continued into the first two performance years.

Pennsylvania Rural Health Model (PARHM)
The approach to payment reform in this Model attracted a range of participants from a variety of hospital types (e.g., critical access hospitals, prospective payment system, independent, system-affiliated, and varying financial status). However, hospital participation has been lower than anticipated, resulting in challenges to achieving scale targets and a smaller share of revenue covered by the global budget. Medicare’s fixed, biweekly payments helped participants manage fluctuations in volume and provided financial stability. Additionally, while the Model contributes to short-term financial stability, independent rural hospitals continue to struggle with long-term sustainability. Some hospitals opted for long-term financial stability through system acquisition and mergers. Large cost savings also may not be feasible in the Model due to the limited timeline to realize significant spending reductions and to the hospitals’ tight operation margins.