COVID-19

The Transition Forward from the COVID-19 Public Health Emergency

PPP Loans

SBA and Treasury Announce PPP Re-Opening; Issue New Guidance | U.S. Department of the Treasury

Physician Self-Referral

https://www.cms.gov/Medicare/Fraud-and-Abuse/PhysicianSelfReferral/index?redirect=/physicianselfreferral/

Self-Referral Disclosure Protocol

https://www.cms.gov/medicare/fraud-and-abuse/physicianselfreferral/self_referral_disclosure_protocol

Changes Effective March 1, 2023

On December 28, 2022, the Office of Management and Budget approved revisions to the SRDP Disclosure Form and related forms that providers of services and suppliers must use in order to utilize the SRDP. The updated forms can be found here. Providers of services and suppliers must use the updated forms for disclosures submitted on or after March 1, 2023. The updated forms may be used for disclosures submitted prior to March 1, 2023.

New HIPAA Regulations in 2023

https://www.hipaajournal.com/new-hipaa-regulations/

Bottom Line: what does the May 11 end of HHS’s Telehealth HIPAA enforcement discretion mean?

Federal Register/Vol. 85. No. 77/Tuesday, April 21, 2020/Rules and Regulations

Under this Nonfiction, covered health care providers may use popular applications that allow for video chats, including Apple Face Time, Facebook Messenger video chat, Google Hangouts video, zoom, or Skype to provide telehealth without risk that OCR might seek to impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency.

1. Since March 2020, providers have been allowed to use non-HIPAA compliant video chat applications to deliver telehealth services

2. On May 11, this policy of “enforcement discretion” will end & HHS’s Office of Civil Rights (OCR) will resume enforcement of penalties on providers for noncompliance with HIPAA rules for telehealth technology use

Quality Payment Program – MIPS/MACRA

MIPS Extreme and Uncontrollable Circumstances (EUC) exception application deadline extended until March 3, 2023

https://qpp.cms.gov/mips/traditional-mips

https://documents.cap.org/documents/2022-mips-clinical-quality-measures-guide.pdf

http://2022 Summary of Cost Measures – cms.gov

2020 Extreme and Uncontrollable Circumstances Fact Sheet.pdf

Quality Payment Program – MIPS

CMS Releases 2018 Quality Payment Program Performance Data

Posted 1/6/2020

Today, the Centers for Medicare and Medicaid Services (CMS) released the final 2018 performance data for the Quality Payment Program. We announced the preliminary data earlier this year, and now we have released additional data elements that show significant success and participation in both the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Model (APM) paths

We heard from you that this program was a big change for many clinicians and we worked with you to improve the program. Therefore, we are pleased to announce that clinician participation rates and success in QPP increased from 2017 to 2018.

2018 Performance Highlights

The final 2018 performance feedback data revealed:

98% of eligible clinicians participated in MIPS in 2018— up from 95% in 2017
98% of eligible clinicians exceeded the performance threshold score of 15 points to receive a positive payment adjustment— up from 93% in 2017
356,353 clinicians participated in MIPS through APMs— up from 341,220 in 2017

Moving Forward

We continue with our commitment to building a program that is fully transparent and provides accurate information. We are also committed to continuing to provide the MIPS performance data points that, based on your feedback, will be most useful to you right now. Additionally, we plan to provide a comprehensive 2018 MIPS Experience Report in the coming months that documents national trends for MIPS eligibility, participation, and reporting.

For a complete breakdown of the 2018 performance data, please see our blog post and 2018 Quality Payment Program Performance Year Data Infographic.