HHS updates Provider Relief Fund reporting guidance again

The Department of Health and Human Services (HHS) again modified its guidance around Provider Relief Fund (PRF) post-payment reporting requirements. Among other changes, HHS updated its definition of “lost revenues,” now defined as the difference between the 2019 and 2020 actual revenues from patient care. Previous guidance from September articulated a more restrictive view of what constituted “lost revenues” and drew concern from MGMA and other groups that HHS was narrowing the range of permitted uses of PRF payments. While this October update is a welcomed change, MGMA will continue to engage with HHS on PRF-related issues and advocate for improvements and clarifications.

Advanced APM participants: Review public notice for missing payments by Nov. 13

Following reports of missing payments, MGMA is advising all members that participated in an advanced APM in 2018 and earned a 5% bonus in 2020 to review CMS files to confirm that none of their clinicians eligible for an incentive bonus failed to receive a payment. CMS listed the names of clinicians it was unable to disburse payment to because of missing billing information in an Excel document contained in this 2020 QP Notice for APM Incentive Payment zip file. In order to receive payments, these clinicians or someone on their behalf will need to verify their Medicare billing information by Nov. 13, 2020. The zip file contains additional instructions.

Even group practices that have already received a 2020 APM bonus payment and believed it to be complete should check this file for their clinicians' names. Several MGMA members in APMs were missing payments for certain clinicians, despite receiving an earlier payment to their tax identification number (TIN). It appears that CMS could not locate updated billing information for many physician assistants, in particular. The agency has not conveyed why there were issues with this provider type, but they appear to be disproportionately represented in the list of clinicians with missing billing information.
 

2019 QPP preliminary performance results released

CMS released additional information about aggregate 2019 performance in the Quality Payment Program (QPP) for both the MIPS and APM track. Some highlights include:

• 6.83% (65,237) of MIPS eligible clinicians had one or more MIPS categories re-weighted due to the COVID-19-related extreme and uncontrollable circumstances policy.
• 1.79% is the maximum positive MIPS payment adjustment in 2021 (for those that earned a perfect MIPS score in 2019).
• The number of QPs in advanced APMs increased slightly in 2019 to 195,564 (from 183,306 in 2018).

CMS also released supplemental data from the 2018 performance year of MIPS that provides more detail at the TIN/national provider identifier level. This information is sortable by variables like clinician type, practice size, scores, and payment adjustments. This may be helpful for those interested in drilling down on performance results.