As the COVID-19 crisis continues to unfold, DataGen is closely monitoring news and updates from CMS and other sources. We’ll be updating this section frequently; here are a few of the trackers we have been looking at:
- Institute for Health Metrics and Evaluation’s COVID-19 Projections
- Johns Hopkins Center for Systems Science and Engineering COVID-19 Global Cases
While CMS has not provided definitive answers on how Bundled Payments for Care Improvement-Advanced (BPCI-A) or the Oncology Care Model will be impacted, we are cautiously optimistic that CMS will be announcing flexibility for participants in these programs.
- BPCI-A: The CMS Innovation Center is currently assessing the flexibilities in BPCI-A model participation due to extraordinary challenges model participants are likely facing. Visit the CMS “COVID-19 Partner Toolkit” webpage for timely and helpful information for providers and beneficiaries.
- OCM:CMS is also reviewing the potential impact COVID-19 may have on total cost of care for OCM practices and will share information as it becomes available.
- CJR’s extreme and uncontrollable circumstances policy will be modified to apply to participant hospitals affected by the COVID-19 pandemic. The proposed policy would apply to episodes that occur during the declared state of emergency or were initiated within 30 days prior to the emergency declaration. In addition, performance year 5 of the current CJR program will be extended by 3 months and will now end on March 31, 2021.
- The Shared Savings Program extreme and uncontrollable circumstances policy will be applied to the COVID-19 pandemic for the duration of the public health emergency that began in January 2020. Shared losses will be mitigated for ACOs that are participating in a performance-based risk track. Furthermore, ACOs whose participation expires at the end of the year will be given the option to extend for an additional year and ACOs required to increase their level of financial risk in their current agreement period will have the option to maintain their current level of risk for the next year.
The CARES Act:
On March 27, 2020, Congress responded to the COVID-19 emergency by adopting the Coronavirus Aid, Relief and Economic Security (CARES) Act, the most massive economic recovery legislation in United States history. DataGen released an analysis on the provider-specific impacts of the CARES Act, including:
- elimination of 2% sequestration, which will run from May 1 to Dec. 31, 2020, and extension of the sequester from the end of 2029 to through 2030;
- removal of the incremental calendar year 2021 reduction to Medicare payment rates for Clinical Laboratory Fee Schedule services and the extension of the 15% cap to CY 2024;
- elimination of the $4 billion in Medicaid Disproportionate Share Hospital cuts in federal fiscal year 2020 and reduction of the cut from $8 billion to $4 billion for FFY 2021; and
- the waiver of the long-term care hospital 50% rule during the emergency period.
Several payment changes adopted in the CARES Act were not included in our analysis due to lack of data and/or full detail on implementation, including the Medicare add-on that increases the weight of the hospital Diagnosis Related Group for treating COVID-19 patients by 20%.
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