Monday Morning Rounds with CMS

ICYMI, here is recent communication from CMS.

CMS Releases 2021 Final Rule for the Quality Payment Program – CMS published the final policies for the 2021 performance year of the Quality Payment Program (QPP) via the Medicare Physician Fee Schedule (PFS) Final Rule.

Reminder: 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 312020 Promoting Interoperability Hardship Exception Application period closes. Clinicians, groups, and virtual groups who believe they are eligible for this exception may apply, and if approved, will qualify for a re-weighting of the MIPS Promoting Interoperability performance category. 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 (note: may not appear in the tool until the submission window opens in 2021).
  • December 31 – 2021 virtual group election period closes. Solo practitioners and groups with 10 or fewer clinicians (including at least one MIPS eligible clinician) who want to participate in MIPS as a virtual group for the 2021 performance year must submit their election to CMS.
  • January 4, 2021 – 2020 MIPS performance year data submission window opens.
  • February 1, 20212020 Extreme and Uncontrollable Circumstances Application period closes. Clinicians, groups, and virtual groups who believe they are eligible for this exception may apply, and if approved, will qualify for a re-weighting of one or more MIPS performance categories. CMS will notify applicants via email whether their requests are approved or denied. If approved, the exception will be added to the QPP Participation Status Tool.
    • New: CMS has finalized that for the 2020 performance year, Alternative Payment Model (APM) Entities may submit Extreme and Uncontrollable Circumstances applications as a result of COVID-19. For more information about the impact of COVID-19 on Quality Payment Program participation, see the Quality Payment Program COVID-19 Response webpage.
  • March 1, 2021 – Deadline for CMS to receive 2020 claims for the Quality performance category. Claims must be received by CMS within 60 days of the end of the performance period. Deadline dates vary to submit claims to the MACs. Check with the MACs for more specific instructions.
  • March 31, 2021 – 2020 MIPS performance year data submission window closes.

CMS will be hosting a virtual Town Hall meeting on January 7th to share updates on the Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) policy considerations. The event will also be an opportunity for stakeholders to provide feedback on MVP considerations for future implementation.

To further support clinicians during the COVID-19 public health emergency, CMS is extending the 2020 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances Exception application deadline to February 1, 2021. For the 2020 performance year, CMS will be using our Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency.

CMS Announces New Model to Advance Regional Value-Based Care in Medicare – CMS announced a new and transformative voluntary payment model that builds on CMS’ focus to deliver Medicare beneficiaries value through better care and improved quality. The Geographic Direct Contracting Model (the Model) will test an approach to improving health outcomes and reducing the cost of care for Medicare beneficiaries in multiple regions and communities across the country. Through the model, participants will take responsibility for beneficiaries’ health outcomes, giving participants a direct incentive to improve care across entire geographic regions.

In the 2021 Medicare Physician Fee Schedule (PFS) Final Rule, CMS has finalized its previous proposal to allow Alternative Payment Model (APM) Entities to submit an application to reweight Merit-based Incentive Payment System (MIPS) performance categories as a result of extreme and uncontrollable circumstances. In addition, CMS has extended the application deadline to February 1, 2021.

CQMC Releases Additional Core Measure Sets Aimed at Improving Transition to Value-Based Care – As the nation’s health care system transforms from one that pays for volume to one that pays for value, there is a growing need for useful performance measures to help assess the quality of care being delivered by physicians in a value-based payment (VBP) arrangements. The Core Quality Measures Collaborative (CQMC) released four revised core measure sets as well as two new core sets tailored to specific specialties and designed to improve patient outcomes, reduce the burden on health care providers, and give consumers and payer information on which to assess physician performance.

Reminder: Extended Deadline to Update Your Billing Info by December 13 for Your APM Incentive Payment – CMS Quality Payment Program website includes 2020 Alternative Payment Model (APM) Incentive Payment details. To access information on the incentive amount and organization paid, clinicians and surrogates can log in to the QPP website using their HARP credentials. In order to receive payments, certain clinicians will need to verify their Medicare billing information by December 13, 2020.

CMS has added new performance information to the Doctors & Clinicians section of Medicare Care Compare and in the Provider Data Catalog (PDC), the successor websites to Physician Compare and the Physician Compare Downloadable Database. Medicare patients and caregivers can use the Care Compare website to search for and compare doctors, clinicians and groups who are enrolled in Medicare. Publicly reporting 2018 Quality Payment Program performance helps empower patients to select and access the right care from the right provider.

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From CMS Innovation Center

The Centers for Medicare & Medicaid Services Innovation Center, also known as “CMMI,” develops and tests new healthcare payment and service delivery models.

Announced: CHART Model – Applications for the Community Transformation Track are due by February 16, 2021
Through the Community Health Access and Rural Transformation (CHART) Model, CMS aims to continue addressing disparities by providing a way for rural communities to transform their health care delivery systems by leveraging innovative financial arrangements as well as operational and regulatory flexibilities.

Announced: Medicare Advantage Value-Based Insurance Design Model
Through the Medicare Advantage Value-Based Insurance Design (VBID) Model, CMS is testing a broad array of complementary Medicare Advantage (MA) health plan innovations designed to reduce Medicare program expenditures, enhance the quality of care for Medicare beneficiaries, including those with low incomes such as dual-eligibles, and improve the coordination and efficiency of health care service delivery.

Announced: Geographic Direct Contracting Model
The Geographic Direct Contracting Model (also known as the Model or Geo) is a new payment and care delivery model being tested by the Centers for Medicare & Medicaid Services (CMS) Innovation Center. The Model will test whether a geographic-based approach to care delivery and value-based care can improve health and reduce costs for Medicare beneficiaries across an entire geographic region.

Announced: Radiation Oncology Model, Final rule posted
The Radiation Oncology (RO) Model aims to improve the quality of care for cancer patients receiving radiotherapy (RT) and move toward a simplified and predictable payment system. The RO Model tests whether bundled, prospective, site neutral, modality agnostic, episode-based payments to physician group practices (PGPs), hospital outpatient departments (HOPD), and freestanding radiation therapy centers for radiotherapy (RT) episodes of care reduces Medicare expenditures while preserving or enhancing the quality of care for Medicare beneficiaries. The RO Model has a 4.5-year Model performance period that begins on July 1, 2021 and runs through December 31, 2025.