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Updated on May 9, 2024

Posted April 2022

Reimbursement

  • COVID-19 PHE is Renewed Through July 15
    • CMS continues to gradually end some emergency blanket waivers allowed under the COVID-19 public health emergency (PHE) for some providers, but for now the 1135 waivers remain intact for acute care and critical access hospitals. The current 90-day PHE declaration was renewed and posted online Wednesday, and is effective through July 15.
  • Telehealth Place of Service Code: Effective for date of service on or after January 1, 2022, the Center for Medicare and Medicaid Services (CMS) allowed the new telehealth place of service (POS) code 10 - telehealth provided in patient's home. The telehealth POS change was implemented on April 4, 2022. Read the complete update

Outpatient

  • Did you know that Targeted Probe and Educate (TPE) is resuming? Visit the Noridian Medicare Website for more information and upcoming webinars. Additional information can be found on the CMS website at Targeted Probe and Educate | CMS
  • DMEPOS Items: Medical Record Documentation. For Medicare to cover any Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) item, the patient's medical record must include enough documentation to justify the need for the a) type and quantity of items ordered and b) frequency of use (or replacement if applicable). Read the complete update
  • Prior Authorization (PA) for Certain Hospital Outpatient Department (OPD) Services Webinar - May 10, 2022
  • New WOPD and Face-to-Face Required List HCPCS Code Look Up Tool - Now Available: Did You Know we have a New WOPD and Face-to-Face Required List HCPCS Code Lookup Tool? This tool will assist suppliers and billers determine which HCPCS codes require a written order prior to delivery (WOPD) and face-to-face (F2F) encounter. Effective April 13, 2022, HCPCS codes listed in the Federal Register will require a WOPD and F2F within six months preceding the date of the WOPD. The tool can be found on the Noridian website.

Inpatient

Post acute

Quality

Outpatient

  • The new #MIPS Value Pathways (MVPs) reporting framework will begin in performance year 2023 with 7 MVPs. Want to learn how choosing this participation option will benefit you and your patients? Watch CMS' new video for an overview
  • 2022 CAHPS for MIPS Overview Fact Sheet (PDF)
  • Quality Performance Category: Traditional MIPS Requirements - Performance Year 2022
    • Groups, virtual groups, and Alternative Payment Model (APM) Entities with 25 or more clinicians (including at least one MIPS eligible clinician) can register through June 30, 2022, to use the CMS Web Interface for reporting quality measures under traditional MIPS. See 
    • CAHPS for MIPS Survey
      • If your group, virtual group, or APM Entity participating in traditional MIPS registers for and meets the sampling requirements for the CAHPS for MIPS Survey, this may count as 1 of the 6 required measures or can be reported in addition to the 10 measures required for the CMS Web Interface.

Inpatient

  • Advancing Health Equity: CMS Proposes Policies to Advance Health Equity & Maternal Health, Support Hospitals
    • Health equity means the attainment of the highest level of health for all people, where everyone has a fair and just opportunity to attain their optimal health regardless of race, ethnicity, disability, sexual orientation, gender identity, socioeconomic status, geography, preferred language, or other factors that affect access to care and health outcomes. To address health care disparities in hospital inpatient care and beyond, CMS is proposing three health equity-focused measures for adoption in the Hospital Inpatient Quality Reporting (IQR) Program. The first measure assesses a hospital’s commitment to establishing a culture of equity and delivering more equitable health care by capturing concrete activities across five key domains, including strategic planning, data collection, data analysis, quality improvement, and leadership engagement. The second and third measures capture screening and identification of patient-level, health-related social needs—such as food insecurity, housing instability, transportation needs, utility difficulties, and interpersonal safety. By screening for and identifying such unmet needs, hospitals will be in a better position to serve patients holistically by addressing and monitoring what are often key contributors to poor physical and mental health outcomes.

Posted March 2022

Reimbursement

  • Inpatient Rehabilitation Facilities: Fiscal Year 2023 Proposed Rule - Submit Comments by May 31. On March 31, CMS issued the fiscal year 2023 inpatient rehabilitation facility (IRF) prospective payment system proposed rule to update Medicare payment policies and rates. See a summary of key provisions.Proposals include:
    • Updating payment rates by 2.8%, with estimated overall payments to increase by 2.0% after productivity and outlier adjustments
    • Applying a permanent 5% cap on annual wage index decreases
    • Expanding quality data reporting on all IRF patients, regardless of payer
  • Noridian: Manipulated, Reconstituted and/or Injectable Amniotic and Placental Derived Products
    • The public notice issued on 2/23/22 has been rescinded as of 3/25/22. Further direction on previously processed and newly submitted claims will be forthcoming. Please continue to watch our website and Listserv email for further direction. Read the complete update

Posted November 2021

Reimbursement

  • Noridian's Final Wound and Ulcer Care LCD (L38902) and Associated Billing and Coding: Wound and Ulcer Care Article (A58565) - Effective November 28, 2021
  • HCPCS Application Summaries & Coding Decisions: 510(k)-Cleared Wound Care Products
  • Modifier 59, National Correct Coding Initiative (NCCI) and Medically Unlikely Edit (MUE) Webinar - November 30, 2021 This event includes: National Correct Coding Initiatives (NCCI), Procedure to Procedure (PTP) CCI Edits, Modifier 59, Medically Unlikely Edits (MUEs), Correct Coding Initiative (CCI) Examples, Resources
  • Targeted Probe and Educate (TPE) A/B Webinar - December 15, 2021 This event includes: TPE Process, Initiating Reviews, Provider Notification, Completing and Closing File, and Resources
  • CMS Physician Payment Rule Promotes Greater Access to Telehealth Services, Diabetes Prevention Programs. On November 2, CMS is announcing actions that will advance its strategic commitment to drive innovation to support health equity and high quality, person-centered care. CMS’ Calendar Year (CY) 2022 Physician Fee Schedule (PFS) final rule will promote greater use of telehealth and other telecommunications technologies for providing behavioral health care services, encourage growth in the diabetes prevention program, and boost payment rates for vaccine administration. The final rule also advances programs to improve the quality of care for people with Medicare by incentivizing clinicians to deliver improved outcomes.
    • To further improve the quality of care for people with Medicare, the PFS final rule makes several key changes to CMS’ Quality Payment Program (QPP), a value-based payment program that promotes the delivery of high-value care by clinicians through a combination of financial incentives and disincentives. For example, CMS finalized a higher performance threshold that clinicians will be required to exceed in 2022 to be eligible for positive payment incentives. This new threshold was determined in accordance with statutory requirements for the QPP’s Merit-based Incentive Payment System (MIPS).
    • CMS is also moving forward with the next evolution of QPP and officially introducing the first seven MIPS Value Pathways (MVPs)  ̶  subsets of connected and complementary measures and activities, established through rulemaking, that clinicians can report on to meet MIPS requirements. MVPs are designed to ensure more meaningful participation for clinicians and improved outcomes for patients by more effectively measuring and comparing performance within different clinician specialties and providing clinicians more meaningful feedback. This initial set of MVP clinical areas include: rheumatology, stroke care and prevention, heart disease, chronic disease management, lower extremity joint repair (e.g., knee replacement), emergency medicine, and anesthesia.
    • CMS is implementing a recent statutory change that authorizes Medicare to make direct Medicare payments to Physician Assistants (PAs) for professional services they furnish under Part B. For the first time, beginning January 1, 2022, PAs will be able to bill Medicare directly.
    • Payments to primary care specialists that involve more clinical labor, such as family practice, geriatrics, and internal medicine specialties, are expected to increase. This increase will to drive greater person-centered care for these services particularly for disadvantaged groups and underserved communities. There will be a four-year transition period to implement the clinical labor pricing update, which will help maintain payment stability and mitigate any potential negative effects on health care providers by gradually phasing in the changes over time.
  • Final Policies for the Medicare Diabetes Prevention Program (MDPP) Expanded Model for the Calendar Year 2022 Medicare Physician Fee Schedule
  • CMS OPPS/ASC Final Rule Increases Price Transparency, Patient Safety and Access to Quality Care
    • Price Transparency of Hospital Standard Charges: Beginning January 1, 2022, CMS will increase the penalty for some hospitals that do not comply with the Hospital Price Transparency final rule. Specifically, CMS is setting a minimum civil monetary penalty of $300 per day that will apply to smaller hospitals with a bed count of 30 or fewer, and a penalty of $10 per bed per day for hospitals with a bed count greater than 30, not to exceed a maximum daily dollar amount of $5,500. Under this approach, for a full calendar year of noncompliance, the minimum total penalty amount would be $109,500 per hospital, and the maximum total penalty amount would be $2,007,500 per hospital.
    • Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs: CMS is also enhancing beneficiary protections by finalizing policies that will allow for a more evidence-based approach in determining whether procedures should be payable in the outpatient setting. In the CY 2021 OPPS/ASC final rule, CMS finalized a policy to eliminate the Inpatient Only (IPO) list over a three-year period, removing 298 services in the first phase of the elimination. A large number of stakeholder comments opposed elimination of the list, primarily due to safety concerns with performing certain procedures in an outpatient setting. For CY 2022, CMS is halting the elimination of the IPO list and, after clinical review of the services removed from the list in CY 2021, CMS is adding all but a small number of procedures back to the list. CMS is also reinstating the ASC Covered Procedures List (CPL) criteria that were in effect in CY 2020 and adopting a process for stakeholders to nominate procedures they believe meet the requirements to be added to the ASC CPL
  • Final Policies for the Medicare Diabetes Prevention Program (MDPP) Expanded Model for the Calendar Year 2022 Medicare Physician Fee Schedule
  • Fiscal Year (FY) 2022 Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) PPS Changes
  • Home Health Value-Based Purchasing (HHVBP) Model Expanded Nationwide : Throughout 2022, CMS will provide technical assistance to HHAs to ensure they understand how performance will be assessed. The first performance year will begin January 1, 2023. Adjustments will be made to HHA Medicare fee-for-service payments in 2025, according to their performance in 2023. 
  • CMS Finalizes Calendar Year 2022 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model Expansion

Quality

  • Resources Available: For individuals working with a Qualified Clinical Data Registry (QCDR) who are planning on submitting quality measures, promoting interoperability measures, and/or improvement activities for the 2021 Merit-based Incentive Payment System (MIPS) performance year, a list of all approved QCDRs can be found here 
  • The Medicare Promoting Interoperability Program requires participants to report on four self-selected electronic clinical quality measures (eCQMs) from the set of nine available. The data submission deadline is February 28, 2022. Click here to learn more. 
  • CMS Publishes 2022 PFS Final Rule for the Quality Payment Program. 
    • Register for the November 10 Overview of the 2022 Quality Payment Program Final Rule Webinar
    • 2022: QPP Final Rule Highlights. Key QPP policies in the 2022 performance year include:
      • Revising the definition of a MIPS eligible clinician to include social workers and certified nurse mid-wives.
      • Setting the MIPS performance threshold at 75 points and the exceptional performance threshold at 89 points.
      • Weighting the cost and quality performance categories equally (as statutorily required) at 30%.
      • Extending the CMS Web Interface as a collection type and submission type in traditional MIPS for registered groups, virtual groups, and APM Entities for the 2022 performance year only.
      • Finalizing a longer transition for electronic clinical quality measures (eCQMs)/MIPS clinical quality measures (CQMs) measure reporting for Shared Savings Program Accountable Care Organizations (ACOs) by extending the CMS Web Interface as an option for 3 years (through the 2024 performance year).
    • 2023 and Beyond: QPP Final Rule Highlights – Additional Finalized Policies. The following updates were also included in the PFS Final Rule and affect future years of the QPP:
      • Finalizing 7 MVPs that will be available, beginning with the 2023 performance year.
      • Providing a description of the registration process and timeline for MVP and subgroup registration, beginning with the 2023 performance year.

Posted October 2021

Reimbursement

Posted September 2021

Clinical

Telehealth/ telemedicine

  • Hospitals Plan For Telehealth Expansion Despite Declining Use and Clinicians Show Intent to Continue Telehealth Use Post-Pandemic. 
    • In a survey with 100 responses performed by KLAS Research and the Center for Connected Medicine, more than 80 percent of hospitals and health systems reported that telehealth visits comprised 20 percent or less of their total appointments during the two-month span. However, hospitals are still interested in expanding telehealth services, to better manage patient populations while keeping costs down. The top three areas for future telehealth expansion cited by survey respondents were chronic care management, behavioral health and urgent care.
    • In a study with 207 responses, participants anticipated continuing use of virtual visits with an average of 43.9% post-pandemic. Overall, 74.5% of participants were satisfied with their experience using virtual visits, and 88% believed they could incorporate virtual visits well within the usual workflow. Participants highlighted some challenges in offering virtual care. For example, 58% were concerned about patients’ limited access to technology, 55% about patients’ knowledge of technology, and 41% about the lack of integration with their current EMR, the increase in demand over time, and the connectivity issues such as inconsistent Wi-Fi/Internet connection.
  • The Biden administration in August gave $19 million in grants to expand telehealth in rural and underserved communities, with the funding allocated to help train primary care providers, bolster groups providing virtual care, pilot new telehealth services and research the efficacy of digitally delivered care in rural areas. The $19 million will be distributed to 36 awardees through the HHS Health Resources and Services Administration.
  • Where the US stands on telehealth coverage: 13 states with emergency orders that ended or will end soon and how they are approaching telehealth coverage. Illinois, Maine and Wisconsin have or will transition to permanent telehealth coverage policies.
  • Back in July 2021, CMS proposed to expand Telehealth Coverage in Proposed 2022 Physician Fee Schedule. The proposal includes expanding Medicare coverage for telehealth services that address mental health and substance abuse issues and extending most COVID-19 freedoms until the end of 2023, as well as some coverage for FQHCs and RHCs.

Reimbursement

Posted August 2021

Quality

  • FDA recommends UHMS-accredited hyperbaric facilities for treatment of specific illnesses
    • In a July 26 release entitled “Hyperbaric Oxygen Therapy: Get the Facts” the U.S. Food and Drug Administration (FDA) has cleared the use of hyperbaric oxygen therapy (HBOT/HBO2) for the treatment of several conditions. The release further states: “If your health care provider recommends HBOT, the FDA advises you get the treatment at a hospital or facility that has been inspected and is accredited by the Undersea and Hyperbaric Medical Society.
    •  The agency advises that individuals seeking hyperbaric oxygen therapy check with their health care provider to make sure they are pursuing the most appropriate care, noting that some facilities operate outside recognized FDA guidelines. “The FDA is aware there are some hyperbaric oxygen treatment centers promoting hyperbaric oxygen chambers for uses that have not been cleared or approved by the FDA, such as treatment of cancer, Lyme disease, autism, or Alzheimer’s disease.”

Posted July 2021

Reimbursement

  • CY 2022 Physician Fee Schedule Proposed Rule with Comment Period: The CY 2022 Medicare Physician Fee Schedule Proposed Rule with comment period was placed on display at the Federal Register on July 13, 2021. This proposed rule updates payment policies, payment rates, and other provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2022. This proposed rule proposes potentially misvalued codes and other policies affecting the calculation of payment rates. It also proposes to make certain revisions to telehealth services in accordance with the Consolidated Appropriations Act, 2021 (CAA). Additionally, it proposes amendments to telehealth regulatory requirements regarding interactive telecommunications systems and solicits comments on documentation, audio-only, and program integrity guardrails. It also makes several proposals that consider recent changes to Evaluation and Management (E/M) visit codes, such as the current policies for split (or shared) E/M visits, critical care services, and services furnished by teaching physicians involving residents. The proposed rule also proposes modifications to the de minimis standard for therapy services and updates a payment regulation for Medical Nutrition Therapy (MNT) services. Additionally, it includes a comment solicitation on several important considerations regarding vaccine administration services. CMS will accept comments on the proposed rule until September 13, 2021, and will respond to comments in a final rule. The proposed rule can be downloaded from the Federal Register at: https://www.federalregister.gov/public-inspection.
  • Autologous Platelet-Rich Plasma (PRP) for Chronic Non-Healing Wounds: Effective for claims with dates of service on or after April 13, 2021, Medicare started to accept and pay for autologous PRP for the treatment of chronic non-healing diabetic wounds for a duration of 20 weeks, when prepared by devices whose Food and Drug Administration-cleared indications include the management of exuding cutaneous wounds, such as diabetic ulcers.

Posted March 2021

Clinical

Quality

  • Doctors and Clinicians Preview Period is ending soon on March 25, 2021 The Doctors and Clinicians Preview Period ends on March 25, 2021 at 8 p.m. ET (5 p.m. PT). If you haven’t previewed your information already, don’t miss your chance to preview your 2019 Quality Payment Program (QPP) performance information before it is publicly reported on clinician and group profile pages on Medicare Care Compare and in the Provider Data Catalog (PDC) . Access the secure preview through the QPP
  • Register for the 2021 Quality Payment Program Overview Webinar. CMS will answer questions from attendees at the end of the webinar as time permits. Webinar Details Title: 2021 Quality Payment Program Overview Date: Thursday, April 8, 2021 Time: 2:00 – 3:30 p.m. ET
  • REMINDER: The MIPS 2020 Data Submission Period is Open MIPS Eligible Clinicians Can Submit Data for 2020 through March 31 The data submission period for Merit-based Incentive Payment System (MIPS) eligible clinicians who participated in the 2020 performance year of the Quality Payment Program (QPP) ends at 8:00 p.m. EDT on March 31, 2021.

Posted January 2021

Quality

  • Reminder: 2020 MIPS Extreme and Uncontrollable Circumstances Exception Application Deadline for COVID-19 has been Extended to February 1, 2021
  • The Centers for Medicare & Medicaid Services (CMS) has posted many new Quality Payment Program (QPP) resources to the QPP Resource Library
  • The Centers for Medicare & Medicaid Services (CMS) is announcing the beta release of the redesigned data.cms.gov website. The goal of the website redesign is to make it easier for users to discover, access, and understand CMS data. CMS is publicly releasing https://data.cms.gov/beta/ 
  • Check Your Initial 2021 MIPS Eligibility on the QPP Website; CMS Finalizes New MIPS Reporting Framework

Reimbursement

  • NEW CMS TRAINING EVENT – Section M: Skin Conditions - Assessment and Coding of Pressure Ulcers/Injuries Web-Based Training. Can be accessed via the Skilled Nursing Facility Quality Reporting Program Training 
  • Home Health Value-Based Purchasing (HHVBP) Model Expansion. The U.S. Department of Health and Human Services (HHS) is announcing that HHS Secretary, Alex M. Azar, II, has approved the expansion of the Home Health Value-Based Purchasing (HHVBP) Model.  The HHVBP expansion would be implemented through rulemaking no earlier than January 1, 2022.
  • On December 27, the Consolidated Appropriations Act, 2021 modified the Calendar Year (CY) 2021 Medicare Physician Fee Schedule (MPFS): Provided a 3.75% increase in MPFS payments for CY 2021, Suspended the 2% payment adjustment (sequestration) through March 31, 2021, Reinstated the 1.0 floor on the work Geographic Practice Cost Index through CY 2023, Delayed implementation of the inherent complexity add-on code for evaluation and management services (G2211) until CY 2024, CMS has recalculated the MPFS payment rates and conversion factor to reflect these changes. The revised MPFS conversion factor for CY 2021 is 34.8931. The revised payment rates are available in the Downloads section of the CY 2021 Physician Fee Schedule final rule (CMS-1734-F) 

Posted December 2020

Reimbursement

  • On December 1, CMS released the annual Physician Fee Schedule (PFS) final rule, emphasizing permanent expansion of Medicare Telehealth Services and improved payment for time doctors spend with patients. Key takeaways: 
    • Payment update. With the budget neutrality adjustment, as required by law, to account for changes in RVUs including significant increases for E/M visit codes, the final CY 2021 PFS conversion factor is $32.41, a decrease of $3.68 from the CY 2020 PFS conversion factor of $36.09.
    • Medicare Telehealth and Other Services Involving Communications Technology: more than 60 services were added to the Medicare telehealth list that will continue to be covered beyond the end of the PHE. These additions allow beneficiaries in rural areas who are in a medical facility (like a nursing home) to continue to have access to telehealth services such as certain types of emergency department visits, therapy services, and critical care services. Medicare does not have the statutory authority to pay for telehealth to beneficiaries outside of rural areas or, with certain exceptions, allow beneficiaries to receive telehealth in their home. However, this is an important step, and as a result, Medicare beneficiaries in rural areas will have more convenient access to health care. See other updates in the blog post "Reimbursement for Telemedicine Services in Wound Care".
    • Direct Supervision by Interactive Telecommunications Technology: For the duration of the COVID-19 PHE, direct supervision may be provided using real-time, interactive audio and video technology through the later of the end of the calendar year in which the PHE ends or December 31, 2021.
    • Payment for Office/Outpatient Evaluation and Management (E/M) and Analogous Visits: As finalized in the CY 2020 PFS final rule, in CY 2021 CMS will be largely aligning its E/M visit coding and documentation policies with changes laid out by the CPT Editorial Panel for office/outpatient E/M visits, beginning January 1, 2021. The final rule makes changes to evaluation and management services and codes, including increasing the relative value of several services, such as maternity care bundles and end-stage renal disease capitated payment bundles.
    • Policies Regarding Professional Scope of Practice and Related Issues: 
      • Supervision of Diagnostic tests by Certain Nonphysician Practitioners (NPPs): CMS is finalizing our proposal to make permanent following the COVID-19 PHE, the same policy that was finalized under the May 1, 2020 COVID-19 IFC (85 FR 27550 through 27629) for the duration of the COVID-19 PHE to allow nurse practitioners (NPs), clinical nurse specialists (CNSs), physician assistants (PAs), and certified nurse-midwives (CNMs) to supervise the performance of diagnostic tests within their scope of practice and state law.  We are adding certified registered nurse anesthetists (CRNAs) to this list.
      • Medical Record Documentation: In the CY 2020 PFS final rule, CMS finalized broad modifications to the medical record documentation requirements for physicians and certain NPPs. In this CY 2021 PFS final rule, we are clarifying that physicians and NPPs, including therapists, can review and verify documentation entered into the medical record by members of the medical team for their own services that are paid under the PFS. We are also clarifying that therapy students, and students of other disciplines, working under a physician or practitioner who furnishes and bills directly for their professional services to the Medicare program, may document in the record so long as the documentation is reviewed and verified (signed and dated) by the billing physician, practitioner, or therapist
  •  Centers for Medicare & Medicaid Services (CMS) released the final Outpatient Prospective Payment System rule that sets payment rates for hospital services starting on Jan. 1. 
    • Under the 2021 OPPS final rule, CMS will pay for 340B-acquired drugs at the average sales prices of the drug minus 22.5 percent versus an older payment methodology in which CMS paid the average sales price plus 6 percent.
    • CMS also finalized a 2.4 percent increase in reimbursements to ASCs in 2021.

Clinical

Posted November 2020

Clinical

  • CMS Launches Hospital-at-Home Program to Free Up Hospital Capacity. Centers for Medicare & Medicaid Services (CMS) outlined unprecedented comprehensive steps to increase the capacity of the American health care system to provide care to patients outside a traditional hospital setting amid a rising number of coronavirus disease 2019 (COVID-19) hospitalizations across the country. These flexibilities include allowances for safe hospital care for eligible patients in their homes and updated staffing flexibility designed to allow ambulatory surgical centers (ASCs) to provide greater inpatient care when needed
  • New reports show increase in home health referrals during pandemic
  • CMS announced that it will retire the original compare tools Dec. 1. Released in early September, Care Compare at Medicare.gov replaces the original compare tools, including Nursing Home Compare, Hospital Compare, and Physician Compare. See https://www.medicare.gov/care-compare/
  • CMS Urging Nursing Homes to Follow Established COVID Guidelines This Holiday Season. Today, in advance of the approaching holiday season, the Centers for Medicare & Medicaid Services (CMS) is urging nursing home staff, residents and visitors to follow established guidelines for visitation and adherence to the core principles of infection prevention.

Posted October 2020

Clinical

Reimbursement

Posted September 2020

Clinical

Reimbursement

Quality

Posted August 2020

Clinical

Reimbursement

Posted July 2020

Announcement

  • RATIONALE, STUDY DESIGN CONSIDERATIONS, AND PROTOCOL RECOMMENDATIONS FOR TREATING COVID-19 PATIENTS WITH HYPERBARIC OXYGEN: Posted July 28, 2020 at UHMS.org - The UHMS Research Committee has completed their "Rationale, Study Design Considerations, and Protocol Recommendations for Treating Covid-19 Patients with Hyperbaric Oxygen" report.  As SARS-CoV-2 infection accelerated in early 2020, many patients deteriorated rapidly and became ventilator-dependent. The death rate from serious infection was frightening, especially in patients with other chronic diseases. Clinicians and medical researchers began developing strategies to treat and prevent this new worldwide public health threat. They looked to novel interventions because no highly effective therapies existed, and care was mostly supportive. Some recommended hyperbaric oxygen (HBO2) therapy because of its demonstrated success in providing oxygen and reducing end-organ damage in patients with severe carbon monoxide poisoning or anemia. Read more
  • HHS extended the public health emergency declared for the COVID-19 pandemic Thursday, according to a tweet from Secretary Alex Azar. Extending the PHE allows a number of regulatory changes that have been enacted to help providers manage outbreaks of the novel coronavirus to continue, including the rollback of telehealth restrictions that have eased access to virtual visits.
  • Coronavirus Disease 2019 (COVID-19) Provider Burden Relief Frequently Asked Questions (FAQs) - Posted July 2020 by CMS. Is CMS suspending most Medicare Fee-For-Service (FFS) medical review during the Public Health Emergency (PHE) for the COVID-19 pandemic? 
  • Effective July 1, 2020, (as posted on the Undersea and Hyperbaric Medicine LinkedIn page) NBDHMT has approved the use of live-streaming in accordance with the following information and guidelines detailed in this letter. Please be sure the joint provider you attend an Introductory Course in Hyperbaric Medicine with has approval through UHMS and NBDHMT for live streaming before registering. A full listing of approved ICHM courses is on the UHMS website here: https://lnkd.in/e5E2w2F.  Currently, International ATMO and Wound Care Education Partners are approved to host live-streaming of their ICHM courses and meet all UHMS standards. Other joint providers are pending approval, so please email stacy@uhms.org for more up to date information. UHMS approval is separate from NBDHMT, so please check with both organizations, if applicable.

Compliance

  • RAC Audits Expected During the COVID Pandemic - New post on medicaidlaw-nc by kemanuel: Even though the public health emergency (“PHE”) for the COVID pandemic is scheduled to expire July 24, 2020, all evidence indicates that the PHE will be renewed. I cannot imagine a scenario in which the PHE is not extended, especially with the sudden uptick of COVID.  Center for Medicare and Medicaid Services (CMS) has given guidance that the voluminous number of exceptions that CMS has granted during this period of the PHE may be extended to Dec. 1, 2020.
  • Notice of Non-Compliance Related to Annual Payment Update. Quality Reporting Program: Non-Compliance Letters for FY2021 APU CMS is providing notifications to facilities that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for CY 2019, which will affect their FY 2021 Annual Payment Update (APU).  Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 18, 2020.

Clinical 

  • Vaccines for COVID-19. Part 1: The Good, the Bad, the Ugly - by Caroline Fife, M.D. | Jul 27, 2020 | COVID-19, Guest Blog by Dr. Marissa Carter: There are currently over 140 SARS-cov2 vaccine candidates. Many of those will likely fail at some point due to lack of funding, poor efficacy, or unacceptable side effects but it is hoped that sufficient number will complete phase III trials and be acceptable to the regulatory authorities. It’s understandable to hope that a vaccine might do more than protect us from COVID-19 pneumonia.
  • Defining the Role of Hyperbaric Oxygen Therapy as an Adjunct to Reconstructive Surgery.: Surg Clin North Am. 2020 Aug;100(4):777-785. doi: 10.1016/j.suc.2020.04.003. Epub 2020 Jun 17. Review.  The discipline of reconstructive surgery has been slow to accept the role of hyperbaric oxygen therapy (HBOT) as an adjunct to surgery, despite clinical and experimental data showing potential benefits. Obstacles prevent this acceptance; one of the most potent is surgeon bias. 
  • Five Things About Nursing Homes During COVID-19: On July 9, CMS shared Five Things About Nursing Homes During COVID-19, part of an ongoing series by HHS. Safeguarding the health and well-being of the most vulnerable and fragile Americans is a top priority for the Trump Administration. Watch to hear from Administrator Seema Verma about five things CMS is doing to stop the spread of coronavirus in nursing homes.
  • COVID-19: Lessons from the Front Lines Call — July 17. Friday, July 17 from 12:30 to 2 pm ET. These calls are a joint effort between CMS Administrator Seema Verma, Food and Drug Administration (FDA) Commissioner Stephen Hahn, MD, and the White House Coronavirus Task Force. Physicians and other clinicians: Share your experience, ideas, strategies, and insights related to your COVID-19 response. There is an opportunity to ask questions. To Participate:
    • Conference lines are limited; we encourage you to join via audio webcast
    • Or, call 833-614-0820; Access Code: 3096434

Reimbursement

Quality

  • CY 2020 Updates to the Quality Payment Program
    •  MIPS VALUE PATHWAYS starting with the 2021 MIPS performance period:  In the CY 2020 PFS proposed rule (84 FR 40735), CMS proposed to apply a new MVP framework beginning with the 2021 MIPS performance period/2023 MIPS payment year to simplify MIPS, improve value, reduce burden, help patients compare clinician performance, and better inform patient choice in selecting clinicians. As discussed in section III.K.3.a.(2) of this final rule, CMS is finalizing a modified proposal to define MVPs at § 414.1305 as a subset of measures and activities established through rulemaking.
      • CMS intends to develop MVPs in collaboration with stakeholders that align with guiding principles that include simplification and clinician burden reduction. CMS intends to work with stakeholders to develop MVPs that account for variation in specialty, size, and composition of clinician practices. CMS also intends that MVPs would allow for a more cohesive participation experience by connecting activities and measures from the 4 MIPS performance categories that are relevant to a patient population, a specialty or a medical condition, reducing the siloed nature of the current MIPS participation experience. 
      • For more details see MIPS Value Pathways
  • Spring/Summer 2020 Quality Payment Program Exception Applications Window Opens: If you seek a Quality Payment Program Extreme and Uncontrollable Circumstances Exception or a Hardship Exception to the Promoting Interoperability performance category, you will be able to apply for this between Spring 2020 and December 31, 2020. 

Posted June 2020

Announcement

Compliance - HIPAA 

Reimbursement

Clinical

  • COVID-19 Has Made the Office Visit a Dinosaur: By IHI Multimedia Team | Wednesday, June 24, 2020 - The office visit has been central to modern medicine. Long-held truths include the necessity of meeting with patients in person, lining up patients to see them in order, and care team members efficiently doing their part to maximize the physician’s precious time and skills. COVID-19 has shown that this choreography is often unnecessary.
  • Tracking COVID-19
    • New Global Confirmed Cases (on 6/9): 117,052
    • New U.S. Confirmed Cases (on 6/9): 18,061
    • Total U.S. Deaths (as of 6/9): 112,311

Posted May 2020 

Compliance - HIPAA

Reimbursement

Clinical

  • Guest Blogger Marissa Carter, PhD On COVID-19 and What Happens Next by Caroline Fife, M.D. | May 12, 2020 - What Happens Next for the USA?  While there are a great many more blogs to write about COVID-10 from my perspective, before we go any further, we need to have an in-depth discussion on the epidemiology of the virus, so some things that weren’t clear to you now will be, especially as we are going to incorporate many of these items in further discussion.
  • Respiratory conditions in coronavirus disease 2019 (COVID-19): Important considerations regarding novel treatment strategies to reduce mortality. - A novel virus named 2019 novel coronavirus (2019-nCoV/SARS-CoV-2) causes symptoms that are classified as coronavirus disease (COVID-19). Respiratory conditions are extensively described among more serious cases of COVID-19, and the onset of acute respiratory distress syndrome (ARDS) is one of the hallmark features of critical COVID-19 cases. 
  • Home Health Plans of Care: NPs, CNSs and PAs Allowed to Certify - Section 3708 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L. No. 116-136) amended sections 1814(a) and 1835(a) of the Social Security Act to allow Nurse Practitioners (NPs), certified Clinical Nurse Specialists (CNSs), and Physician Assistants (PAs) to certify beneficiaries for eligibility under the Medicare home health benefit and oversee their plan of care. This is a permanent change that will continue after the Public Health Emergency. Effective for claims with dates of service on or after March 1, 2020, these non-physician practitioners may bill the following codes:
    • G0179: Physician re-certification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians to affirm the initial implementation of the plan of care
    • G0180: Physician certification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians to affirm the initial implementation of the plan of care
    • G0181: Physician supervision of a patient receiving Medicare-covered services provided by a participating home health agency (patient not present) requiring complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans
    • The descriptors of the three codes will be revised at a later date to include the non-physician practitioner specialties.
  • HBOT in a Tyson COVID-19 Outbreak, Part 4: "I Can’t Stop Smiling" - by Caroline Fife, M.D. | May 7, 2020 | COVID-19, COVID-19 & HBOT 
  • HBOT in a Tyson COVID-19 Outbreak, Part 3 - by Caroline Fife, M.D. | May 6, 2020 | COVID-19, COVID-19 & HBOT 
  • HBOT in a Tyson COVID-19 Outbreak, Part 2: “It’s Incredible” - by Caroline Fife, M.D. | May 5, 2020 | COVID-19, COVID-19 & HBOT
  • HBOT in a Tyson COVID-19 Outbreak, Part 1: Keeping it Real  - by Caroline Fife, M.D. | May 4, 2020 | COVID-19, COVID-19 & HBOT

Posted April 2020

Compliance - HIPAA

Reimbursement

Clinical

Clinical Trials

  • Safety and Efficacy of Hyperbaric Oxygen for Improvement of Acute Respiratory Distress Syndrome in Adult Patients With COVID-19; a Randomized, Controlled, Open Label, Multicentre Clinical Trial  Brief Summary: We hypothesize that hyperbaric oxygen (HBO) is safe for patients with COVID-19 and that HBO reduces the inflammatory reaction in Acute Respiratory Distress Syndrome (ARDS) associated with COVID-19. Also known as SARS-CoV-2, COVID-19 is declared a pandemic by World Health Organization (WHO). No specific treatment has been successful as of March 2020. Mortality rates in patients that develop ARDS is extremely high, 61.5-90%, almost double the mortality of ARDS of any cause. ARDS associated with COVID-19 is associated with pulmonary edema, rapidly progressing respiratory failure and fibrosis. The mechanism behind the rapid progress is still an enigma but theories have evolved around severe inflammatory involvement with a cytokine storm. Macrophage activation is involved in the early phase of ARDS and cytokine modulators have been tried in experimental settings without proven clinical benefits. HBO significantly reduces inflammatory cytokines and and oedema in other clinical settings. HBO has been used for almost a century, nowadays mainly used for its anti-inflammatory effects. Several randomized clinical trials show beneficial effects in variety of inflammatory diseases including diabetic foot ulcers and radiation injury. HBO is generally regarded as safe with very few adverse events and extensive experimental and clinical evidence suggest that HBO is a promising drug to ameliorate ARDS associated with COVID-19.
  • Hyperbaric Oxygen for COVID-19 Patients - NIH U.S. National Library of Medicine, Clinical Trials.gov -  Brief Summary: Hyperbaric oxygen therapy (HBOT) treatment will be provided to patients as an adjunct to standard therapy for a cohort of 40 COVID19-positive patients with respiratory distress at NYU Winthrop Hospital. All patients prior to the clinical application of HBOT will be evaluated by the primary care team and hyperbaric physician. After the intervention portion of this study, a chart review will be performed to compare the outcomes of intervention patients versus patients who received standard of care.

Quality

  • CMS flexibilities to fight COVID-19 (3/30/20) Changes to MIPS:  CMS is making two updates to the Merit-based Incentive Payment System(MIPS) in the Quality Payment Program. CMS is modifying the MIPS Extreme and Uncontrollable Circumstances policy to allow clinicians who have been adversely affected by the COVID-19 public health emergency to submit an application and request reweighting of the MIPS performance categories for the 2019 performance year. This is an important change that allows clinicians who have been impacted by the COVID-19 outbreak and may be unable to submit their MIPS data during the current submission period, to request reweighting and potentially receive a neutral MIPS payment adjustment for the 2021 payment year. Additionally, CMS is adding one new Improvement Activity for the CY 2020 performance year that, if selected, would provide high-weighted credit for clinicians within the MIPS Improvement Activities performance category. Clinicians will receive credit for this Improvement Activity by participating in a clinical trial utilizing a drug or biological product to treat a patient with COVID-19 and then reporting their findings to a clinical data repository or clinical data registry. This would help contribute to a clinicians overall MIPS final score, while providing important data to help treat patients and address the current COVID-19 pandemic.

Posted March 2020

Reimbursement

  • 2020 Telehealth Expansion During Emergency Webinars - Medicare made changes to the telehealth guidelines for services provided during the COVID-19 emergency. WPS will hold two webinars to discuss these changes. Our education provides an overview of telehealth services and the CMS changes during the emergency. We will also discuss other communication technology-based services available. 

                            04/02/2020 - 8:30 AM - 10:00 AM CT (9:30 AM - 11:00 AM ET) Register at http://wpsghalearningcenter.com/confirm-course?courseid=7MZ-HsyrHdc1

                            04/09/2020 - 1:00 PM - 2:30 PM CT (2:00 PM - 3:30 PM ET) Register at http://wpsghalearningcenter.com/confirm-course?courseid=_o4jeWat3ho1

Clinical

Safety

Posted February 2020

Reimbursement

Quality

Clinical

Posted January 2020

Reimbursement

  • Late Night Thoughts on HBOT Prior Authorization – About the Centers for Medicare & Medicaid Services (CMS) Daily Digest Bulletin by Caroline Fife, M.D. | Jan 23, 2020 | Healthcare Payment Policy
  • Quality Payment Program: New MIPS Participation Framework for 2021 Performance Period. CMS is implementing a new participation framework for the Merit-based Incentive Payment System (MIPS) starting with the 2021 performance period, MIPS Value Pathways (MVPs). The goal of this new framework is to move away from siloed performance category measures and activities and toward an aligned set of measures and activities that are more meaningful to clinicians and patient care.
  • 2020 Physician Fee Schedules RevisedOn December 20, 2019, the President signed the Further Consolidated Appropriations Act of 2020 (FCAA). The FCAA updates the CY 2020 Medicare Physician Fee Schedule (MPFS).
  • Changes in the Level of Supervision of Outpatient Therapeutic Services in Hospitals and Critical Access Hospitals (CAHs): Effective January 1 2020, CMS has changed the minimum required level of supervision for hospital outpatient therapeutic services furnished by all hospitals and CAHs from direct supervision to general supervision. General supervision means that the procedure is furnished under the physician's overall direction and control, but that the physician's presence is not required during the performance of the procedure. This change ensures a standard minimum level of supervision for each hospital outpatient therapeutic service furnished incident to a physician’s service. As stated in the final rule with comment period, this change does not preclude a hospital from requiring a higher level of supervision for certain services, as it determines appropriate.
  • Payment for Procedures Involving Skin Substitutes: For CY 2020, CMS finalized its proposal to continue the policy to assign skin substitutes to the low-cost or high-cost group, while CMS continues to consider comments received on episode-based payment or a single category of payment for services involving such products for future policy refinement.

Clinical

Posted December 2019

Reimbursement

Clinical

Posted November 2019

Reimbursement

  • Two new Price Transparency Requirements have been announced. One of the rules is the Calendar Year (CY) 2020 Outpatient Prospective Payment System (OPPS) & Ambulatory Surgical Center (ASC) Price Transparency Requirements for Hospitals to Make Standard Charges Public Final Rule. The second rule is the Transparency in Coverage Proposed Rule. Both the final and proposed rules require that pricing information be made publicly available.
  • Physician Fee Schedule and OPPS/ASC Final Rules have been published  
  • Bill Correctly for Medicare Telehealth ServicesCMS released the Medicare Telehealth Services Video to help you bill correctly.
  • Skilled Nursing Facility Claims Hold. As CMS has undertaken the implementation of the Patient Driven Payment Model (PDPM), we are holding a limited number of Skilled Nursing Facility (SNF) claims while we make further refinements to our claims processing system. PDPM is a historic reform of the SNF prospective payment system. PDPM focuses on the patient’s condition and resulting care needs rather than on the amount of care provided in order to determine Medicare payment. PDPM was effective on October 1, 2019. Specifically, CMS is holding claims with:
    • Dates of service October 1, 2019 or later and
    • Type of Bill (TOB) inpatient services (21X) and swing bed services (18X) subject to SNF Patient Driven Payment Model (PDPM) and
    • Multiple line items, Health Insurance Prospective Payment System (HIPPS) codes, with different rate codes (revenue code 0022).
  • CMS Finalizes Calendar Year 2020 Payment and Policy Changes for Home Health Agencies. In November 2018, CMS finalized a new case-mix classification model, the Patient-Driven Groupings Model (PDGM), effective beginning January 1, 2020. The final rule with comment period also increases Medicare payments to home health agencies (HHAs) by an estimated 1.3 percent ($250 million) for calendar year (CY) 2020.
    •  CMS is implementing the Patient-Driven Groupings Model (PDGM), a new case-mix payment methodology for home health services, which more accurately pays for home health services and focuses on patient needs by relying heavily on patient characteristics rather than volume of care. 
    • CMS is addressing potential Medicare fraud by phasing out pre-payments for home health services over the next year and eliminating those payments completely in 2021.
  • Final OASIS D-1 Data Submission Specifications Now Available

Quality

  • Stay on Target with the Hospice Comprehensive Assessment Measure - One Pager Now Available. CMS has posted a document that articulates key information about the Hospice Comprehensive Assessment Measure. This one pager provides a visual to understand how the seven HIS measures contribute to the one Comprehensive Assessment Measure, and how to stay on target by completing all seven HIS measures for each patient. 
  • The submission deadline for the Inpatient Rehabilitation Facility (IRF), Long-Term Care Hospital (LTCH), and Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) has been extended to November 18, 2019.

Clinical

Posted October 2019

Reimbursement

Quality

Clinical

Posted September 2019

Reimbursement

Quality

Clinical

Posted August 2019

  • Centers for Medicare & Medicaid Services Special Open Door Forum Open Payments Expansion under the SUPPORT Act Thursday, August 29, 2019 2:00pm – 3:00pm Eastern Time Conference Call Only.
    • Open Payments is a national disclosure program that promotes a more transparent and accountable health care system by publishing the financial relationships between applicable manufactures and group purchasing organizations (GPOs) and health care providers (physicians and teaching hospitals).
    • In the fall of 2018 President Trump signed the SUPPORT Act into law which expands the Open Payments definition of a covered recipient to include: physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists and certified nurse midwives.

Quality

Clinical

    Posted July 2019

    Reimbursement

    Quality

    Clinical

    Posted June 2019

    Reimbursement

    Quality

    Clinical

    Posted May 2019

    Reimbursement

    Quality

    Clinical

    Posted April 2019

    Reimbursement

    Quality

    Clinical

    Posted March 2019

    Reimbursement

    Quality

    Clinical

    Posted February 2019

    Reimbursement

    Quality

    Clinical

    Posted January 2019

    Reimbursement

        Clinical

        Posted December 2018

          Clinical

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