ASCRS ASOA Release Quality Payment Program (QPP) 2021 Final Rule Guide for Ophthalmic Practices
ASCRS and ASOA have released a comprehensive guide for ophthalmic practices participating in the QPP for 2021. The guide includes the following:
- QPP Overview
- 2021 Key Merit-Based Incentive Payment System (MIPS) Changes
- Guides on each of the Four Categories of MIPS: Quality, Promoting Interoperability, Improvement Activities, and Cost
Guides on Group vs. Individual Reporting and Virtual Groups, Advanced Alternative Payment Models (APMs) and MIPS APMs and MIPS APM Guide for the Alternative Payment Pathway (APP) will be coming soon.
For questions, please contact Jennifer Gallihugh, ASOA Senior Manager of Strategic Initiatives at jgallihugh@asoa.org.
HHS Updates Provider Relief Fund FAQs Focusing on Parent Subsidiary Information, Clarification on the Order of Fund Allocation, and Additional Loss Revenue Calculation Information
HHS has, once again, updated the Provider Relief Fund FAQs. While many of the questions focus on the parent subsidiary information, which are not included here (given the changes related to the Consolidated Appropriations Act, 2021), the highlighted questions below clarify (1) the order in which funds are to be allocated (first to unreimbursed expenses and then to losses) and (2) additional information related to any loss revenue calculation that relies upon having a budget approved on or before March 26, 2020.
Are Reporting Entities required to report each General and/or Targeted Distribution payment separately? (Added 1/28/2021)
Reporting Entities that received General and Targeted Distribution payments will submit a consolidated report through the Provider Relief Fund Reporting Portal.
What is the maximum allotment of my organization’s Provider Relief Fund amount that can be allocated to lost revenue in 2020? (Modified 1/28/2021)
Unreimbursed expenses attributable to coronavirus are considered first in the overall use of funds calculation. Provider Relief Fund payment amounts not fully expended on unreimbursed healthcare related expenses attributable to coronavirus are then applied to lost revenues for 2020.
Is interest earned on Provider Relief Fund funds considered a reportable revenue source to HHS? (Modified 1/28/2021)
Yes, if funds were held in an interest-bearing account, they would be considered reportable revenue. If interest is earned on Provider Relief Fund disbursements that the Reporting Entity expended in full, the interest amounts may be retained and applied toward a reportable use of funds.
If interest is earned on funds that are only partially expended, the interest on remaining unused funds must be calculated, reported, and returned.
Can I use 2020 budgeted revenues as a basis for reporting lost revenues? (Modified 1/28/2021)
Yes. When reporting use of Provider Relief Fund money toward lost revenues attributable to coronavirus, Reporting Entities may use budgeted revenues if the budget(s) and associated documents covering calendar year 2020 were established and approved on or before March 26, 2020. To be considered an approved budget, the budget must have been ratified, certified, or adopted by the Reporting Entity’s financial executive or executive officer as of that date, and the Reporting Entity will be required to attest that the budget was established and approved on or before March 26, 2020. Documents related to the budget, including the approval, must be maintained in accordance with the Terms and Conditions.
Are Reporting Entities required to report each General and/or Targeted Distribution payment separately? (Added 1/28/2021)
Reporting Entities that received General and Targeted Distribution payments will submit a consolidated report through the Provider Relief Fund Reporting Portal.
If an entity incurred enough lost revenue in April and May 2020 to justify its use of the Provider Relief Fund payments received, can it only report those two months? (Modified 1/28/2021)
No. Recipients have multiple options to calculate lost revenue as outlined in the Post-Payment Notice of Reporting Requirements. However, for each of these options, the Reporting Entity must report revenue for the full calendar year 2020. If funds were not expended in full by December 31, 2020, then a second and final report will be required on use of funds for the period January 1, 2021 - June 30, 2021, which is due no later than July 31, 2021.
If an entity received payments totaling over $10,000, but returned some, do they still have to report? (Modified 1/28/2021)
A Reporting Entity must report only when they have retained over $10,000 in aggregated Provider Relief Fund dollars.
If all funds are expended to cover unreimbursed healthcare related expenses attributable to coronavirus, are Reporting Entities still required to submit lost revenue information? (Modified 1/28/2021)
Reporting Entities are required to submit actual patient care revenue for calendar years 2019 and 2020 in order to inform program integrity and HRSA’s audit strategy.
What will be the methodology/formula used to calculate provider payment in Phase 3 General Distributions? (Modified 1/28/2021)
Providers will be paid the greater of up to 88 percent of their reported losses (both lost revenue and health care-related expenses attributable to coronavirus incurred during the first half of 2020) or 2 percent of annual revenue from patient care. Some applicants will not receive an additional payment, either because they experienced no change in revenues or net expenses attributable to COVID-19, or because they have already received funds that equal or exceed reimbursement of 88 percent of reported losses or 2 percent of revenue from patient care.
Certain applicants may not receive these full amounts because HHS determined the revenues and operating expenses from patient care reported on their applications included figures that were not exclusively from patient care (as defined in the instructions), reported figures were not reflected in submitted financial documentation, or reported figures were extreme outliers in comparison to other applicants of the same provider type; instead, HHS capped the amount paid to these provider types based on industry estimates of revenue and operating expenses from patient care.
What is the payment amount that an applicant should expect to receive from Phase 3 of the General Distribution? (Modified 1/28/2021)
If an applicant has not yet received and kept a payment that is approximately 2 percent of annual revenue from patient care as part of either Phase 1 or 2 of the General Distribution, then they will receive at least that amount in Phase 3 payment. In addition to this amount, providers will be paid up to 88 percent of their reported losses (both lost revenue and health care-related expenses attributable to coronavirus incurred during the first half of 2020) if losses exceeded 2 percent of annual revenue from patient care. Some applicants may not receive this proportion of the losses reported on their applications, because HHS determined the reported revenues and operating expenses from patient care were not exclusively from patient care (as defined in the instructions) or because reported figures were not reflected in submitted financial documentation. Additionally, some applicants will not receive an additional payment either because they experienced no change in revenues or net expenses attributable to COVID-19, or because they have already received funds that equal or exceed reimbursement of 88 percent of reported losses.
Democrats Move Forward on Biden Administration’s $1.9 Trillion COVID Relief Package, Negotiations Continue
Early this morning, February 5, 2021, the Senate approved the budget resolution on party lines by a vote of 50 – 50, with Vice President Harris breaking the tie, which provides budget reconciliation instructions for the $1.9 trillion COVID relief package. This followed the required 50-hour clock for debate and vote-a-rama, where over 800 amendments were submitted in an effort to slow down the process. Because changes were made through this amendment process, some with bipartisan support, the House voted today on final approval by a vote of 219 to 209, even though the House approved the budget resolution earlier in the week by a vote of 218 to 212. This will lead to the reconciliation package next week, with the goal of a floor vote the last week in February.
The budget resolution is a shell bill, which authorizes the $1.9 trillion COVID relief package with instructions to the committees on drafting legislation under reconciliation, and negotiations will continue. On Thursday, the 10 Republican senators, who met with President Biden on their suggested COVID relief package, sent a letter raising questions on the structuring of the relief checks and the amount of education funding.
Biden Administration Delays and Withdraws Additional Health Rules
As we have reported, the Biden administration has acted to delay the effective date of several Trump regulations. The Organ Procurement Organizations Conditions for Coverage final rule, which altered the requirements related to organ procurement organizations (OPOs), was scheduled to take effect on February 1 but is now delayed until March 30 to provide the new administration time to review “issues of fact, law, and policy.” The White House also delayed the Trump administration’s drug rebate rule, which would replace current rebates with fixed-fee arrangement, delaying the policy until March 22 from an original effective date of January 29.
HHS is also delaying the Secure Electronic Prior Authorization for Medicare Part D rule, originally slated to go into effect January 30, until March 30. The rule streamlines the prior authorization process for certain products in Part D. The White House has also withdrawn three rules proposed by the Centers for Medicare and Medicaid Services (CMS) during the Trump administration: Conditions for Coverage for End-Stage Renal Disease Facilities—Third Party Payments; Strengthening Oversight of Accrediting Organizations (AO) and Preventing AO Conflict of Interest, and Related Provisions; and Revisions to Medicare Part A Enrollments.
GAO Releases Latest Report On COVID-19 Response
The Government Accountability Office (GAO) released a report asserting that the Trump administration failed to act on the agency’s past recommendations to improve the federal government’s response to the COVID-19 pandemic. As of January, 27 of the agency’s previous 31 recommendations had not been implemented. The GAO’s latest report contains 13 new recommendations to improve the nation’s health and economic recovery, including the creation of a comprehensive coronavirus testing strategy and a coordinated vaccine distribution plan.