The Center for Medicare and Medicaid Services (CMS) has been working to provide as many flexibilities as possible to support practices and clinicians during the COVID-19 pandemic. CMS has added options to reduce reimbursement, rural health, and provider barriers that might otherwise upsurge COVID cases if flexibilities were not allowed. Additionally, CMS has released various hardship offerings and timeline changes to further support practices and clinicians involved in various Value Based Care reporting and performance programs. Nevertheless, practices and clinicians must still be ready to face unforeseen challenges in reporting and performance during and after the COVID-19 Public Health Emergency (PHE).
CMS has released several FAQ’s to assist practices, clinicians, and 3rd party intermediaries supporting practices and clinicians in understanding quality measures that are available for reporting under the Merit-based Incentive Payment System (MIPS), which can be accessed here. While these resources are very helpful, there are still obstacles that reporting individuals and groups should be aware of to avoid penalty under the MIPS program. Currently, there are limitations to screening measures as they require therapy, treatment, or assessments that cannot be conducted via telehealth. Practices that utilize the measures that are not eligible for telehealth may experience performance impacts during the 2020 performance year and ultimately in the form of payment adjustments during the resulting 2022 payment adjustment year.
Through the Medicare Shared Savings Program, a voluntary program that encourages a collaborative effort for managing the entire continuum of care for a patient population, providers share financial and medical responsibility to provide high quality care while limiting unnecessary spending. The majority of activities that measure performance under this alternative payment model allow for telehealth as a means for conducting services and being credited for managing patient care. However, as an example, the PREV-13: Statin Therapy for the Prevention and Treatment of Cardiovascular Disease measure does not allow statin therapy documentation to be completed during a telehealth encounter, but the providers are still held accountable for carrying out this action on the patients they manage.
The National Committee for Quality Assurance (NCQA) has been working to shift the Healthcare Effectiveness Data and Information Set (HEDIS) measures to telehealth compatible over the past few years. According to the NCQA blog, ‘COVID-19 and Telehealth Expansion’ [1] 90% of HEDIS measures have been transformed to be telehealth compatible over the past few years. That still leaves 10% of measures that are not telehealth compatible during the pandemic, which providers and practices are continuing to be scored and possibly penalized on. due to the COVID-19 pandemic, some practices have increased telehealth services up to 80% or even 90% of services rendered. The Interim Final Rule on ‘Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency’ does a significant amount to deal with several limitations of care and restrictions for telehealth service costs to practices and clinicians. Additionally, we see that some initiatives, like those of NCQA over the past few years to transform 90% of HEDIS quality measurements to be telehealth compatible. However, there will still be significant impacts to the quality of care provided to patients and to the providers of that care under various Value-Based Care models. Stay tuned as CMS developments are communicated on COVID-19 and the impact of telehealth services on practices, clinicians, and patients.
[1] Carter, Jazmyne (2020) ‘COVID-19 and Telehealth Expansion’. NCQA Blog, March 2020. Available at https://blog.ncqa.org/covid-19-and-telehealth-expansion/