CMS Clarifies Latest Modification to Rules

May 26, 2020

As a consultant within the healthcare industry, a large portion of my time is spent on the front-lines working directly with the teams and individual staff members that help deliver service to patients. The nurses, physicians, medical assistants, and various support staff are the people who have direct contact with patients and their families on a daily basis. I also get to spend a lot of time with the teams and employees behind the scenes that assist the first group of healthcare workers to deliver that healthcare. The IT staff, data analysts, revenue cycle experts, compliance staff, and finance teams; all of these people, working together, are necessary in order to actually treat and heal patients and provide high-quality healthcare services. They are the people at the forefront of helping others day in and day out; the heroes in scrubs and jackets.

During the COVID-19 pandemic these people have had to face unprecedented levels of stress and uncertainty. Speaking with them it has become apparent that things that were once routine have been upended in a whirlwind of concern, confusion, and constantly evolving narratives. They have had to respond quickly and with unexpected levels of fluidity in order to stay on top of a pandemic that seems to redefine the rules and parameters on an almost weekly basis. The world is in flux.

When I have spoken to any of these heroes over the last two months, the first question they always ask me is “What has changed? What are the new rules?” In this industry, changes to the way healthcare is delivered take a considerable amount of time to be tested, verified, and rolled out on a national level. The timeline is often measured in years, with changes and modifications to improve results extending that time out to half a decade. COVID-19 has drastically changed the world and the rules. Now, changes come down from the national level on an almost weekly basis. The rapid transition from the slow, measured roll-outs to a more nimble system has left many organizations and healthcare workers reeling. It is unsurprising that questions and concern is the first thing I hear in their voice when I speak to them.

It is therefore imperative that healthcare organizations stay on top of all of those changes and modifications in order to effectively treat their patients and ensure that they remain fiscally solvent during this pandemic. The Centers for Medicare and Medicaid Services (CMS) has been rigorous in keeping the healthcare community up to date on all of the modifications to the rules. The changes over the last few weeks have seen more direct guidance in areas that were previously unclear. These include:

· Updates to the Quality Payment Program (QPP) in response to the pandemic
· Extended submission deadlines for the MIPS program
· Price transparency requirements for COVID-19 diagnostic testing
· Toolkits for mitigating COVID-19 within Skilled Nursing Facilities
· Notification requirements for confirmed or suspected COVID-19 cases
· Billing & coding guidance for specimen collection and diagnostic services for COVID-19
· Updates to the Medicare Accelerated and Advance Payments program

Link to updates: https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/Current-Emergencies-page

These clarifying updates have been a direct response to questions from organizations and providers on the front-line combating the effects and spread of COVID-19. And while it would normally be safe to say that these guidelines are the final word, in today’s healthcare climate expect them to be updated regularly as our industry’s understanding and response to COVID-19 becomes more structured.

When the world starts to return to a semblance of normalcy, I look forward to looking my healthcare heroes in the eyes, as opposed to over a Zoom meeting. I look forward to thanking them, in person, for helping to keep us safe. I want to tell them how much it means to me that they are putting themselves at risk to help those who are immuno-compromised. I want to listen as they share their stories, grieve with them over people they lost, and heal with them as we move forward.

In today’s world, not much is certain. The direction and course this industry and this country will take are as yet unknown. However, one thing that is apparent is that in the face of extreme adversity the healthcare community has come together to heal, to help, and to ensure that we all come out of this on the other side.