News You Can Use

COVID-19 & MIPS Reporting Year 2020

Despite the on-going health crisis, the Quality Payment Program is still in full swing for Reporting Year 2020. MIPS practices, ACOs, and APMs are all expected to report their 2020 performance in Q1 2021. So far, CMS has only made some minor alterations to the QPP/MIPS program, largely focused on some “housekeeping-type” changes that will give QCDRs a little more breathing room. That said, CMS has indicated there will be changes coming to the MIPS program, but they have not given a clear timeline or any idea on what will change.

What Has Changed?

  • The biggest change has already come and gone, the data submission deadline for RY 2019 was moved to April 30. Those who did not submit data by that deadline were given a neutral adjustment instead of a penalty as the pandemic trigged an “Extreme and Uncontrollable Circumstances (E&UC) policy” exemption. Practices and providers that did submit will receive their adjustment accordingly.
  • New Improvement Activities (high-weight) for RY2020 were created that promotes participation in COVID-19 treatment clinical trials and reporting on COVID-19 data to a registry or data repository.
  • Extended the deadline for the QCDR measure & collection policies from Jan 1, 2021 to Jan 1, 2022. (This will require QCDRs to follow new rules for gathering more measures and sharing “unique” measures with others)
  • Extended the Call for Quality Measures & the submission of DVER to June 30

What Will Change?

At this point in time, it would be pure speculation as to what will change. The largest lobby groups have advocated for a 90-day reporting window for all four categories, another automatic trigger of the E&UC policy, a nation-wide “pause” on QPP, and other substantive changes. We won’t know until sometime this summer or even this fall if there will be any changes to this reporting year.

Therefore, it is our recommendation to proceed with your RY2020 plans and do not plan on making any modifications to your QPP behavior. Expect that while CMS will make changes, if you continue on the “there’s no change” path you will likely exceed their modified rules whenever they are released.

When CMS does release their changes, we will be here to post an update and provide education to help you understand and best navigate the rules.

COVID Forum Survey

As part of our bi-weekly COVID forums, we want the discussion and guests dictated by you. We also are asked what others are doing to help ‘get back to the norm.’ Here is a 7 question survey to help direct these conversations and then provided back to you in a summary so that you can see what your peers are doing to tackle the challenges of today.

Hospital COVID Forum Survey Link

Physician Practice COVID Forum Survey Link

HHS Announcement – New Relief Funds Distributions for Skilled Nursing Facilities (SNFs)

From the $175 billion provider relief fund, HHS announced this morning that they have allocated an additional $4.9 billion in direct provider relief for Skilled Nursing Facilities (SNFs). HHS has determined the following distribution methodology for SNFs:

  • HHS will make relief fund distributions to SNFs with six or more certified beds based on both a fixed basis and variable basis.
  • Each SNF will receive a fixed distribution of $50,000 plus a distribution of $2,500 per bed.

Consistent with all HHS distributions to this point, nursing home recipients must attest that they will only use Provider Relief Fund payments for permissible purposes, as set forth in the Terms and Conditions, and agree to comply with future government audit and reporting requirements. For further details, you can find the full press release here: https://www.hhs.gov/about/news/2020/05/22/hhs-announces-nearly-4.9-billion-distribution-to-nursing-facilities-impacted-by-covid19.html.

There are reports that distributions began hitting accounts already. So, be on the lookout and let us know if we can be of any assistance

Have you submitted your HHS Revenue Information?

HHS announced this week that you have until June 3rd to submit revenue information for consideration for additional payment from the allocated $50 billion general distribution. While HHS automatically disbursed payments from the first tranche that began April 10th, the majority of physician practices need to submit a request to receive additional funds from this second tranche.

Reminder: Hospital COVID Forum Today

Strategic Healthcare Partners in conjunction with Michele Madison at Morris, Manning & Martin present the COVID-19 Hospital Forum. Hear from subject matter experts along with your peers as they share what is happening and how to respond to it. The Forum is interactive and we encourage you to ask questions of our panelists and each other. Our next call will be Wednesday, May 20th @ 4PM EST.

Join the forum from your computer, tablet, or smartphone:
https://www.gotomeet.me/Strategic-Healthcare/covid-19-hospital-forum

If you need a call-in number, it will be available as an option, with your PIN, after you click the link above.

COVID Forum Reminder

With so much information coming out over the last few days, we anticipate great discussion during the Physician / Manager Forum on Tuesday.  Please join us @ 5:30pEST along with our guest, Michele Madison of Morris, Manning & Martin as we talk through compliance regarding the Payroll Protection Program and HHS Provider Relief Terms & Conditions.

For the best experience, please join our call from your PC or smart device:
https://www.gotomeet.me/Strategic-Healthcare/covid-19-forum

If you do not want to join via app, the call-in information, including your unique PIN, will be generated at the above link.

COVID-19 Tracking Relief Fund Expenditures

COVID-19 Tracking Relief Fund Expenditures

Q. For COVID-19 relief funds, what is needed to properly receive reimbursement or loan forgiveness from the government?

A. The Paycheck Protection Program (PPP) loan program has specific full forgiveness requirements, but the Small Business Administration (SBA) continues to evolve the rules. Fortunately, the Health & Human Services (HHS) distributions of $20 billion & $30 billion has clearly defined “Terms & Conditions” for each type that can be viewed here. We have broken out the most critical elements in our detailed answer below.

HHS $20B & $30B Distribution

Most of you reading this likely received your COVID-19 relief funds from these two general HHS allocations ($20B & $30B). Both distributions have nearly identical Terms and Conditions, both of which state:

  • The Recipient certifies that the Payment will only be used to prevent, prepare for, and respond to coronavirus, and that the Payment shall reimburse the Recipient only for health care related expenses or lost revenues that are attributable to coronavirus.
  • The Recipient certifies that it will not use the Payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse.

Expense Tracking Required

It is clear that organizations will need to carefully document from which of these funds paid for what part of your COVID-19 expenses. SHP recommends an internal tracking mechanism that outlines the following:

  1. PPP – record how this money was spent in accordance with the legislation to maximize forgiveness. Such as: a minimum of 75% on payroll and up to 25% on mortgage/rent/utilities).
  2. $20B Distribution – record how this money was utilized for non-PPP expenses. Allowable items are: lost revenue offsets, additional equipment purchases for PPE, additional office cleaning, and anything that is clearly attributable to coronavirus.
  3. $30B Distribution – Separate from the $20B fund, record how this money was utilized for non-PPP expenses with the same allowable items as the $20B distribution. NOTE: this cannot overlap with the records on how you spent your portion of the $20B distribution! 
    • Example: if you received distributions from both the $20B and $30B program, you cannot use both to pay for the same things. You could use funds from the $20B to pay for PPE, but the funds from the $30B would need to cover something other than PPE expenses.

Conclusion

HHS stated that there will be an additional set of reporting requirements for organizations that received a total HHS distribution over $150,000. As of this publication, HHS has not released these requirements. However, as soon as those are available, we will be sharing via an updated post.

It seems that new guidance is being issued daily, so please don’t hesitate to let us know if you have questions or need help understanding the seemingly ever-shifting documentation burden (send us a message using the form below).

 

Visit our COVID-19 Resource Page for tools and current healthcare news about the coronavirus pandemic.

 

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