• 03/31/2020 11:26 AM | Rebekah Francis (Administrator)

    Last night, the Centers for Medicare & Medicaid Services (CMS) issued a series of temporary regulatory waivers to further support the ability of the nation’s healthcare system to respond to COVID-19. The changes outlined below will take effect immediately across the entire country:

    • New telehealth codes. CMS will pay for 80 additional telehealth codes, including home visits, emergency department visits, and therapy services. Providers can waive copayments for all telehealth services for Original Medicare beneficiaries.
    • Virtual check-ins. Clinicians can provide virtual check-in services (HCPCS G2012, G2010) to both new and established patients. Previously, these services were limited to established patients only.
    • Telephone codes. CMS will reimburse for telephone evaluation and management services provided by a physician (CPT 99441-99443) and telephone assessment and management services provided by a qualified nonphysician healthcare professional (CPT 98966-98968). These codes are only available to established patients but may be furnished using audio-only devices.
    • E-visits. Licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, and speech language pathologists can provide e-visits (HCPCS G2061-G2063). These codes are only available to established patients and must be initiated by the patient.
    • Removal of frequency limitations on Medicare telehealth. Subsequent inpatient visits (CPT 99231-99233), subsequent skilled nursing visits (CPT 99307-99310), and critical care consult codes (CPT G0508-G0509) no longer have limitations on the number of times they can be billed.
    • Medicare physician supervision requirements. Physician supervision can be provided virtually using real-time audio/visual technology for services requiring direct supervision by a physician or other practitioner.
    • “Stark Law” waivers. CMS is implementing waivers that exempt providers from sanctions for noncompliance of certain Stark Law rules, permitting certain referrals and the submission of related claims that would otherwise violate the Stark Law.
    • MIPS flexibilities. CMS will allow clinicians adversely affected by COVID-19 to submit an application to request reweighting of the MIPS performance categories for the 2019 performance year.

    MGMA Government Affairs will continue to educate medical groups as the Administration releases additional waivers and further guidance on COVID-19 related regulatory changes. For a comprehensive list of Medicare telehealth waivers and regulatory developments, please click here.

  • 03/30/2020 1:11 PM | Rebekah Francis (Administrator)

    On Saturday, the Centers for Medicare & Medicaid Services (CMS) announced nationwide expansion of the existing accelerated Advance Payment Program (APP), making the program available for most Medicare physicians and group practices. The APP provides a quick mechanism for healthcare entities to obtain accelerated, interest-free cash flow. Specifically, the APP fact sheet outlines that:

    • Physician practices can request an advanced payment of up to 100% of the Medicare payment amount based on a three-month lookback period. Hospitals can request up to 100% (125% for critical access hospitals) based on a six-month lookback period. The guidance does not specify how the lookback period is determined.
    • Healthcare entities must make a request for an accelerated payment under the APP by submitting a form to their Medicare Administrative Contractor (MAC).
    • Once requested, CMS anticipates MACs will issue payment within seven calendar days from the request.
    • The criteria for applying for the APP are:
    • Having billed Medicare for claims within 180 days immediately prior to the date of request;
    • Not in bankruptcy;
    • Not under active medical review or program integrity investigation; and
    • No outstanding delinquent Medicare overpayments.
    • APP payments are subject to repayment, which for most healthcare entities begins 120 days after the payment is received.
    • During the 120-day period, the healthcare entity will continue to be paid like normal for claims submitted to Medicare.
    • After the 120 days, the recoupment process starts and every claim submitted will be offset to repay the advanced payment.

    This announcement is a step in the right direction; however, MGMA is advocating that the Administration make available funding that is not subject to repayment or recoupment. Recently passed legislation (the CARES Act) creates several financial assistance programs, including $100 billion in grants for Medicare physicians and hospitals. Although the APP fact sheet states that the APP reflects the passage of the CARES Act, which did expand the APP, this program is not part of the $100 billion in funding authorized under that law.   

  • 03/26/2020 12:23 PM | Rebekah Francis (Administrator)

    In response to MGMA calling on the Centers for Medicare & Medicaid Services (CMS) to ease quality reporting and other regulatory requirements, the deadline to submit 2019 MIPS performance data is extended from March 31 to April 30, 2020. MIPS eligible clinicians who have not submitted any MIPS data by April 30 will qualify for an automatic exemption from reporting responsibilities for “extreme and uncontrollable circumstances” and will receive a neutral payment adjustment for the 2021 MIPS payment year. Various other quality reporting programs, such as those applicable to hospitals and post-acute providers, have new flexibilities as well. CMS is also evaluating options for providing relief around participation and data submission for the 2020 performance year. Read more here.

  • 03/26/2020 12:22 PM | Rebekah Francis (Administrator)

    MGMA joined 21 healthcare organizations on a lettercalling on congressional leaders to fully leverage health IT to detect, treat, and prevent the spread of COVID-19. Specifically, the letter urges Congress to address issues including: telehealth and remote patient monitoring, funding to expand rural broadband capabilities, improve the matching of patient medical records, funding for and rapid testing of emerging technologies, and expanded hardship exceptions to protect practices against unfair penalties associated with the Quality Payment Program and other reporting programs.

  • 03/26/2020 12:20 PM | Rebekah Francis (Administrator)

    Late Wednesday night, the Senate passed a much anticipated third emergency funding bill to help combat the spread of the virus and the negative economic impact its having on the country. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act:

    • Provides $100 billion to hospitals and healthcare providers to ensure they continue to receive the support they need for COVID-19 related expenses and lost revenue;
    • creates a “paycheck protection program” that would provide 8 weeks of cash-flow assistance to small employers;
    • Gives the Secretary more flexibility to waive additional Medicare telehealth requirements; and
    • Temporarily suspends the 2% Medicare sequestration.

    The House of Representatives is expected to vote on the bill as soon as tomorrow. MGMA Government Affairs will continue to monitor these legislative developments and provide updates via the COVID-19 Action Center.

  • 03/17/2020 1:36 PM | Rebekah Francis (Administrator)

    Today, the Centers for Medicare & Medicaid Services (CMS) issued guidance on Secretary Azar’s waiver authority that broadens access to Medicare telehealth services. Effective March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, CMS will:

    ·     Waive geographic restrictions, meaning patients can receive telehealth services in non-rural areas;

    ·     Waive originating site restrictions, meaning patients can receive telehealth services in their home;

    ·     Allow use of telephones that have audio and video capabilities; 

    ·     Allow reimbursement for any telehealth covered code, even if unrelated to COVID-19 diagnosis, screening, or treatment; and

    ·     Not enforce the established relationship requirement that a patient see a provider within the last three years.

    The Medicare telemedicine healthcare provider fact sheet can be found here. The Medicare FAQ on these telehealth waivers can be found here. The Enforcement Discretion for telehealth remote communications during the COVID-19 notice can be found here.

    This announcement follows MGMA efforts to encourage CMS to expeditiously expand telehealth coverage in response to the public health emergency. 

    Visit the MGMA COVID-19 Action Center for the latest developments impacting medical practices. 


    Contact MGMA Government Affairs by emailing or calling 202.293.3450, 877.275.6462 toll-free

  • 03/16/2020 3:31 PM | Rebekah Francis (Administrator)

    Due to the spread of COVID-19, President Trump last Friday declared a national emergency, which expands the Administration’s ability to implement regulatory flexibilities through “blanket waivers” of generally applicable Medicare, Medicaid, and CHIP program requirements. When a blanket waiver is issued, it applies broadly and clinicians do not need to apply for individual waiver protection. The Department of Health and Human Services (HHS), together with the Centers for Medicare & Medicaid Services (CMS), has already acted under this authority to implement a number of waivers including:

    ·     Allowing licensed providers to render services outside their state of enrollment for purposes of billing Medicare and Medicaid. 

    ·     Temporarily suspending certain enrollment requirements under Medicare, postponing revalidation actions, and expediting pending or new applications.

    ·     Removing the requirement for a 3-day prior hospitalization prior to coverage of a SNF stay and adding flexibility for obtaining renewed coverage for certain beneficiaries who have recently exhausted SNF benefits.

    ·     Extending certain timelines for filing Medicare Parts B, C, and D appeals.

    These waivers generally have retroactive effect as of March 1. Notably, no waiver around Medicare telehealth coverage and billing has yet been issued. MGMA is closely monitoring this situation and will continue to make updates to our COVID-19 Action Center as they become available. We encourage you to bookmark the COVID-19 Action Center today and check back routinely, as we will be updating it consistently throughout the coming days and weeks.

  • 02/20/2020 3:04 PM | Rebekah Francis (Administrator)

    With physician practices increasingly vulnerable to cyber attacks and other incidents that could lead to patient information being inappropriately revealed, MGMA has developed a new member-exclusive resource to help practice leaders better understand and implement the HIPAA breach requirements. The MGMA HIPAA Breach Toolkit outlines how practices can determine if the disclosure is a reportable breach under the law and what steps the practice must take to inform patients, the federal government, and potentially even local media outlets of the disclosure. In addition, the toolkit discusses the role of business associates in the event of a data breach and offers suggestions on effectively documenting how the breach occurred and the steps practices took following identification of the breach.

  • 02/20/2020 3:03 PM | Rebekah Francis (Administrator)

    In a recent blog post, CMS announced changes to its various public quality performance tools, such as Physician and Hospital Compare. The goal of these tools is to help beneficiaries make informed healthcare decisions, find physicians, and view certain performance data collected from quality reporting programs like MIPS.  

    While there are currently eight independent tools, this spring CMS plans to combine and standardize these existing Compare tools. CMS claims this will permit users to access the same information through a single point of entry and simplify navigation to find the information that is currently divided. This new version will be called Medicare Care Compare. 

    In the past, CMS has established review and dispute periods to correct preliminary datasets. MGMA encourages members to access Physician Compare to ensure the accuracy of data during such periods and will keep members informed about future review opportunities, as well as any further developments about the new Care Compare website.

  • 01/16/2020 8:31 PM | Rebekah Francis (Administrator)

    Some medical group practices have been told to immediately purchase and use Clinical Decision Support Mechanism (CDSM) software to comply with the Appropriate Use Criteria (AUC) program, with vendors suggesting that claims payment would be impacted in 2020. In a posting on its website, the Centers for Medicare & Medicaid Services (CMS) reiterated that 2020 is an educational and operational testing period and there are no payment consequences this year.

    The AUC program will require ordering professionals to consult CDSM software for certain advanced imaging tests and require rendering professionals to include that consultation code on their Medicare claims starting in 2021. Practices are encouraged, however, to plan for implementation of CDSM software and test workflows at some point this year. Access the MGMA AUC Toolkit for additional information on the program.


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