CMS Interim-Final Rule Formalizes, Expands Guidance For COVID-19: Deep Dive Into Coverage and Quality Policy

After receiving feedback from the ACC and other leading medical associations and groups, the Centers for Medicare and Medicaid Services (CMS) issued an interim-final rule this week formalizing many temporary waivers and flexibilities to streamline response to the COVID-19 pandemic. The rule also expands the list of eligible Medicare telehealth services and alters MIPS requirements and extensions. Learn about the telehealth updates here, and blanket waivers and burden relief here.

As part of the final-interim rule, CMS updated the following coverage and quality policies:

Coverage and Quality Policies

  • CMS is amending the extreme and uncontrollable circumstances policy to account for all Innovation Center participant hospitals affected by the COVID-19 pandemic.
  • To the extent an NCD or LCD (including articles) would otherwise require a face-to-face or in-person encounter for evaluations, assessments, certifications or other implied face-to-face services such as TAVR or TMVR, those requirements would not apply during the PHE for the COVID-19 pandemic.
  • To accommodate change healthcare setting needs, CMS will not enforce clinical indications for coverage of anticoagulation NCD 190.11 for Home PT/INR.
  • 2019 MIPS data submission is extended to April 30, 2020.
  • MIPS automatic extreme and uncontrollable circumstances policy will apply to MIPS eligible clinicians, who do not submit their MIPS data by the extended timeline. This means MIPS eligible clinicians, who are not participants in APMs, who do not submit any MIPS data will have all performance categories reweighted to zero percent, resulting in a score equal to the performance threshold, and a neutral MIPS payment adjustment.
  • Temporarily removing the restriction which prevents the application of the Shared Savings Program extreme and uncontrollable circumstances policy for disasters that occur during the quality reporting period if the reporting period is extended, to offer relief under the Shared Savings Program to all ACOs that may be unable to completely and accurately report quality data for 2019 due to the PHE for the COVID-19 pandemic.
  • One new Improvement Activity added for CY2020 performance period: IA_ERP_XX, COVID-19 Clinical Trials.

These temporary program changes and waivers are explained in greater specificity in either the interim-final rule, supplementary fact sheets, or both. See "Related Content" to learn more. ACC staff continue to work with the House of Medicine to monitor regulatory updates and provide feedback to CMS.

Keywords: Coronavirus, ACC Advocacy, Medicare, Centers for Medicare and Medicaid Services (U.S.), COVID-19, Medicaid


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