This week, our In Focus section focuses on five critical policy and program trends to provide integrated care to dual-eligible individuals for Medicare and Medicaid. Both federal and state governments continue to look for ways to improve coordination and integration for this population. We anticipate the emphasis on innovative approaches to whole person, person-centered care, care management and coordination, care transitions, and regulatory oversight to persist. 2020 has been an active year of policymaking by the Centers for Medicare & Medicaid Services (CMS) and states. HMA distilled the themes and their strategic implications in this article. We continue to assist clients in tracking new policies and industry trends, developing innovative plans and strategies, and delivering high quality care and services to this population.
Medicare
CMS Finalizes Meaningful Expansions of Medicare Telehealth Service Coverage Through 2021
This week, our In Focus section reviews the finalized coverage expansions for Medicare telehealth services in the Centers for Medicare & Medicaid Services (CMS) Calendar Year (CY) 2021 Physician Fee Schedule (PFS) Final Rule. Telehealth advocates will be pleased to see meaningful expansions; however, the response of advocates will also be tempered by the impending return of the geographic and site of service limitations that will follow at the conclusion of the COVID-19 Public Health Emergency (PHE). During the PHE, millions of patients and providers increased their use of telehealth services to expand access to care. Given this shift in the delivery of care, telehealth advocates had been hopeful CMS would make extensive permanent coverage expansions in the Medicare program. In light of this, CMS’s new regulation will come as a reminder to many that the key to long term expansions of Medicare telehealth coverage lies in the hands of the U.S. Congress.
CMS Introduces New Medicare Direct Contracting Model Opportunity
This week, our In Focus section looks at a new Medicare model, Direct Contracting, introduced by the Centers for Medicare & Medicaid Services (CMS) Innovation Center. The new model will build on and continue testing potential reforms to the Medicare program encompassed by accountable care organizations (ACOs), Medicare Advantage (MA), and private sector risk-sharing arrangements. The payment model options may appeal to a broad range of physician and provider groups and other organizations because they are expected to introduce flexibility in health care delivery, support a focus on beneficiaries with complex, chronic conditions, and encourage participation from organizations that have not typically participated in traditional fee-for-service (FFS) Medicare or CMS Innovation Center models. However, there will be substantial financial risk—and reward—for participants based on a new, complex methodology, so organizations interested in this new model should carefully consider the possible outcomes from participating in Direct Contracting versus other options. CMS has announced that 51 organizations will participate in the model’s trial Implementation Period, which runs from October 1, 2020, through March 31, 2021. The agency has stated that it expects to announce additional Direct Contracting pathways in the future and that the next round of applications for participation in the second performance year will open in early 2021.
A Short-Term Path to Avoid ACA Uncertainty as the Pandemic Continues
In this week’s In Focus section, Health Management Associates (HMA) Managing Director MMS Matt Powers, Senior Consultant Kaitlyn Feiock, and Regional Vice President Kathleen Nolan look at the future of the Patient Protection and Affordable Care Act (ACA). On November 10, 2020, the Supreme Court of the United States (SCOTUS) heard oral arguments for California v. Texas, challenging the constitutionality and severability of the ACA. This challenge became possible after the 2017 Tax Cuts and Jobs Act, which zeroed out the individual mandate penalty for not purchasing health insurance. While most experts agree that an entire invalidation of the ACA is the least likely outcome based on the oral arguments, some uncertainty remains and more than $100 billion federal funds are at risk. The ACA standardized insurance rules offset premium costs for many individual market consumers and provided authority and funding for Medicaid Expansions in the overwhelming majority of states. The ACA also included other provisions that may be at risk but are not the subject of this note, such as the creation of Center for Medicare and Medicaid Innovation (CMMI) and the Medicare-Medicaid Coordination Office, as well as demonstration authority that has led to the creation of numerous coverage models. As states, Congress, and the federal executive branch face the possibility that the ACA may not survive in its present form, what mitigation strategies are available at the state and federal levels to stabilize uncertainties and protect against abrupt coverage changes?
Evidence-Based Programs Paper Authored by HMA Colleagues
Health Management Associates (HMA), in contract with The National Council on Aging (NCOA), and with support from the Administration for Community Living (ACL), recently provided research and strategy services to support the goal to increase the adoption of evidence-based health promotion and disease prevention programs, known as evidence-based programs (EBPs) by Medicaid, Medicare, and other health insurance markets.
HMA Analysis of 2021 Medicare Advantage Landscape and Mandatory Medicare Radiation Oncology and ESRD Treatment Choices Innovation Models
This week, our In Focus section reviews two recent Medicare developments from the Centers for Medicare & Medicaid Services (CMS). On September 24, 2020, CMS released the Medicare Advantage (MA) and Part D landscape files for the 2021 plan year. These files include information on MA and Part D offerings, including plan types and premiums. Earlier this month, CMS also released a final rule implementing two new mandatory payment models addressing radiation oncology and end-stage renal disease (ESRD).
HMA Summary of Medicare Fee-For-Service (FFS) Proposed Rules
This week, our In Focus section reviews two Medicare fee-for-service (FFS) proposed rules recently issued by the Centers for Medicare & Medicaid Services (CMS). On August 3, 2020, CMS released a proposed rule that includes updates to services furnished under the Medicare Physician Fee Schedule (PFS). On August 4, CMS released the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System proposed rule. These proposed regulations include payment rate and policy changes for the upcoming calendar year. Key features in this year’s PFS proposed rule include: policies to retain, extend, or end certain telehealth flexibilities implemented in response to the novel COVID-19 public health emergency (PHE), changes to enable certain health care professionals to practice at the top of their licenses, modifications to opioid treatment programs (OTPs), and updates to the Medicare Shared Savings Program (MSSP). Additional information on the PFS Proposed Rule can be found here. Among the most notable policy changes in the OPPS and ASC proposed rule are: 1) transitioning services to lower cost settings by eliminating the inpatient-only list to enable more services to be provided in the outpatient settings and increasing the scope of procedures that can be provided in ASCs, 2) further reducing payments for the 340B drug program, and 3) modifying the formula for calculating Hospital Star Ratings, and expand the use of prior authorization for outpatient services. Additional information about these proposals can be found here.
Regulatory Changes to Medicare in Response to COVID-19
This week, our In Focus section examines how the federal government implemented changes to the Medicare program in response to COVID-19. As the COVID-19 pandemic began in the United States, Congress and the Administration responded with a series of legislative, regulatory, and sub-regulatory changes to the Medicare program that were designed to provide relief from certain Medicare rules to assist health care providers, Medicare Advantage organizations, and Part D plans in responding to the pandemic. Some of these changes waived conditions of Medicare participation to enable patients to be treated in alternative care settings. Others permitted physicians and other providers to receive Medicare reimbursements for telemedicine services.
HMA Information Services Adds Medicare Advantage Competitive Data, State Profiles
HMA Information Services (HMAIS) is pleased to announce the expansion of its industry-leading healthcare information website to include information and state-by-state profiles of the market for Medicare Advantage and Special Needs Plans (SNPs).
HMA Announces Cancellation of 2020 Annual Conference
Health Management Associates has made the decision to cancel its October 2020 conference on Trends in Publicly Sponsored Healthcare, given continuing developments concerning COVID-19 and out of an abundance of caution for the safety of attendees, speakers, and staff. Full refunds will be made to registered attendees and sponsors.