2022 News & Updates
May 2022
CMS Releases the Chronic Pain Experience Journey Map
Posted: May 13, 2022
The following message is from the Centers for Medicare & Medicaid Services (CMS):
In late 2019, the Centers for Medicare & Medicaid Services (CMS) launched a Chronic Pain Stakeholder Engagement, which focused on understanding more about access to covered care and services for people with chronic pain. We used qualitative research methods and the human-centered design process to understand and visualize the customer experiences living with, providing care for, and treating people with chronic pain. In addition to direct engagement, CMS leveraged data from the Centers for Disease Control and Prevention.
The intent of the Chronic Pain Experience Journey Map (PDF) is to highlight the most prominent barriers experienced by people accessing care and the influencers acting on providers, ultimately affecting the person with chronic pain, their quality of care, and their quality of life. In collaboration with our Federal partners, we are exploring where opportunities exist for us to address these issues under the authorities we collectively have. We encourage everyone to explore where opportunities exist outside of the parameters of government to bring ease for those suffering with chronic pain, such as eliminating the stigmas that exist not only for those who suffer with chronic pain, but also those who suffer with behavioral health issues as well as those who suffer from opioid use disorder.
CMS recognizes the impact of pain across its programs, and has identified the importance of effective treatment and management of pain in the CMS Behavioral Health Strategy. This work aligns with the CMS Behavioral Health Strategy, the HHS Overdose Prevention Strategy, and important provisions of the SUPPORT Act that address the treatment of pain: Section 6032 which includes a Report to Congress and a CMS Action Plan to Enhance Prevention and Treatment for Opioid Use Disorder, and Section 6086, the Dr. Todd Graham Pain Management Study.
View the Chronic Pain Experience Journey Map (PDF)
Posted: May 13, 2022
The following message is from the Centers for Medicare & Medicaid Services (CMS):
In late 2019, the Centers for Medicare & Medicaid Services (CMS) launched a Chronic Pain Stakeholder Engagement, which focused on understanding more about access to covered care and services for people with chronic pain. We used qualitative research methods and the human-centered design process to understand and visualize the customer experiences living with, providing care for, and treating people with chronic pain. In addition to direct engagement, CMS leveraged data from the Centers for Disease Control and Prevention.
The intent of the Chronic Pain Experience Journey Map (PDF) is to highlight the most prominent barriers experienced by people accessing care and the influencers acting on providers, ultimately affecting the person with chronic pain, their quality of care, and their quality of life. In collaboration with our Federal partners, we are exploring where opportunities exist for us to address these issues under the authorities we collectively have. We encourage everyone to explore where opportunities exist outside of the parameters of government to bring ease for those suffering with chronic pain, such as eliminating the stigmas that exist not only for those who suffer with chronic pain, but also those who suffer with behavioral health issues as well as those who suffer from opioid use disorder.
CMS recognizes the impact of pain across its programs, and has identified the importance of effective treatment and management of pain in the CMS Behavioral Health Strategy. This work aligns with the CMS Behavioral Health Strategy, the HHS Overdose Prevention Strategy, and important provisions of the SUPPORT Act that address the treatment of pain: Section 6032 which includes a Report to Congress and a CMS Action Plan to Enhance Prevention and Treatment for Opioid Use Disorder, and Section 6086, the Dr. Todd Graham Pain Management Study.
View the Chronic Pain Experience Journey Map (PDF)
March 2022
Reminder: MIPS 2021 Data Submission Period Closes 3/31; Other MIPS Update
Posted: March 22, 2022
The following message is from the Centers for Medicare & Medicaid Services (CMS):
Reminder: MIPS 2021 Data Submission is Open through March 31
The data submission period for Merit-based Incentive Payment System (MIPS) eligible clinicians who participated in the 2021 performance year of the Quality Payment Program (QPP) is open. Data can be submitted and updated until 8:00 p.m. ET on March 31, 2022. CMS recently added new 2021 Data Submission Demonstration Videos on its YouTube channel to support submission.
How to Submit Your 2021 MIPS Data
Clinicians will follow the steps outlined below to submit their data:
To sign in and submit data, clinicians will need to register in the HCQIS Authorization Roles and Profile (HARP) system. For clinicians who need help enrolling with HARP, please refer to the Quality Payment Program Access User Guide.
How to Confirm Eligibility
Clinicians who are not sure if they are eligible to participate in the Quality Payment Program can check their final eligibility status using the QPP Participation Status Tool. Clinicians and groups that are opt-in eligible will need to make an election before they can submit data. (No election is required for those who don’t want to participate in MIPS.)
2021 Extreme and Uncontrollable Circumstances (EUC) Application Period Reopened
CMS also reopened the MIPS EUC application for groups, virtual groups, and Alternative Payment Model (APM) Entities that need to cite COVID-19 as the triggering event through March 31, 2022, at 8 p.m. ET. Note: Because of the automatic EUC policy, individual clinicians don’t need to submit an application.
For More Information
To learn more about how to submit data, please review the following resources available on the QPP Resource Library:
Reminder: CMS Recently Reopened the MIPS Extreme and Uncontrollable Circumstances Application for the 2021 MIPS Performance Year in Response to COVID-19
CMS continues to offer flexibilities to provide relief to clinicians responding to the 2019 Coronavirus (COVID-19) public health emergency (PHE). We applied the Merit-based Incentive Payment System (MIPS) automatic extreme and uncontrollable circumstances (EUC) policy to all individual MIPS eligible clinicians for the 2021 performance period.
Recently, we’ve also reopened the MIPS EUC application for groups, virtual groups, and Alternative Payment Model (APM) Entities through March 31, 2022, at 8 p.m. ET. (Because of the automatic EUC policy, you don’t need to submit an application for individual clinicians.) Please note that applications received between now and March 31, 2022, won’t override previously submitted data for groups and virtual groups.
MIPS EUC applications citing COVID-19 as the triggering event can be submitted until Thursday, March 31, 2022, at 8 p.m. ET.
This listserv will review what the MIPS EUC application extension means for:
Official representatives of APM Entities participating in MIPS, including Shared Savings Program ACOs, can submit a MIPS EUC application on behalf of all MIPS eligible clinicians in the APM Entity for the 2021 performance year. If approved, all of the MIPS eligible clinicians in the APM Entity will receive a neutral MIPS payment adjustment in the 2023 MIPS payment year. (Applications must be submitted by an official representative of the APM Entity, and not by a participant in the APM.)
There are some differences from our existing MIPS EUC policy for individuals, groups, and virtual groups:
Posted: March 22, 2022
The following message is from the Centers for Medicare & Medicaid Services (CMS):
Reminder: MIPS 2021 Data Submission is Open through March 31
The data submission period for Merit-based Incentive Payment System (MIPS) eligible clinicians who participated in the 2021 performance year of the Quality Payment Program (QPP) is open. Data can be submitted and updated until 8:00 p.m. ET on March 31, 2022. CMS recently added new 2021 Data Submission Demonstration Videos on its YouTube channel to support submission.
How to Submit Your 2021 MIPS Data
Clinicians will follow the steps outlined below to submit their data:
- Go to the Quality Payment Program webpage.
- Sign in using your QPP access credentials (see below for directions).
- Submit your MIPS data for the 2021 performance year or review the data reported on your behalf by a third party.
To sign in and submit data, clinicians will need to register in the HCQIS Authorization Roles and Profile (HARP) system. For clinicians who need help enrolling with HARP, please refer to the Quality Payment Program Access User Guide.
How to Confirm Eligibility
Clinicians who are not sure if they are eligible to participate in the Quality Payment Program can check their final eligibility status using the QPP Participation Status Tool. Clinicians and groups that are opt-in eligible will need to make an election before they can submit data. (No election is required for those who don’t want to participate in MIPS.)
2021 Extreme and Uncontrollable Circumstances (EUC) Application Period Reopened
CMS also reopened the MIPS EUC application for groups, virtual groups, and Alternative Payment Model (APM) Entities that need to cite COVID-19 as the triggering event through March 31, 2022, at 8 p.m. ET. Note: Because of the automatic EUC policy, individual clinicians don’t need to submit an application.
For More Information
To learn more about how to submit data, please review the following resources available on the QPP Resource Library:
- 2021 Data Submission User Guide
- 2021 APP Data Submission User Guide
- 2021 MIPS Opt-In and Voluntary Reporting Election Guide
- 2021 Data Submission FAQs
- NEW! 2021 Data Submission Demonstration Videos Playlist:
- Reporting as a Group Under the APM Performance Pathway (APP)
- Reporting as a Medicare Shared Savings Program ACO Under the APM Performance Pathway (APP)
- Manual Attestation for Promoting Interoperability Performance Category of MIPS
- Connecting to an Organization as a Practice for MIPS
- Connecting to an Organization APM Entity
- Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.
Reminder: CMS Recently Reopened the MIPS Extreme and Uncontrollable Circumstances Application for the 2021 MIPS Performance Year in Response to COVID-19
CMS continues to offer flexibilities to provide relief to clinicians responding to the 2019 Coronavirus (COVID-19) public health emergency (PHE). We applied the Merit-based Incentive Payment System (MIPS) automatic extreme and uncontrollable circumstances (EUC) policy to all individual MIPS eligible clinicians for the 2021 performance period.
Recently, we’ve also reopened the MIPS EUC application for groups, virtual groups, and Alternative Payment Model (APM) Entities through March 31, 2022, at 8 p.m. ET. (Because of the automatic EUC policy, you don’t need to submit an application for individual clinicians.) Please note that applications received between now and March 31, 2022, won’t override previously submitted data for groups and virtual groups.
MIPS EUC applications citing COVID-19 as the triggering event can be submitted until Thursday, March 31, 2022, at 8 p.m. ET.
This listserv will review what the MIPS EUC application extension means for:
- Groups and virtual groups that haven’t submitted data.
- Groups and virtual groups that have submitted data.
- APM Entities.
- Groups: You don’t need to take any further action if you’re unable to submit data for the 2021 performance period. Group participation is optional, and your individual MIPS eligible clinicians qualify for the MIPS automatic EUC policy. They’ll have all 4 performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless 1) they submit data in 2 or more performance categories as individuals, or 2) the practice reports as a group, by submitting data for one or more performance category.
- Virtual Groups: If you’re unable to submit data for the 2021 performance period, you must submit a MIPS EUC application for all 4 performance categories by the March 31, 2022, deadline.
- Groups and virtual groups that have submitted data for a single performance category:
- If you’re unable to complete data submission for other performance categories, you can submit a MIPS EUC application to request reweighting in the remaining 3 performance categories.
- This includes small practices that were automatically scored as a group on Medicare Part B claims measures submitted throughout the 2021 performance period.
- If you don’t submit a MIPS EUC application, your group will be scored in all performance categories unless you’re eligible for reweighting in one or more performance categories.
- If your application is approved and no additional data is submitted at the group level (or available for scoring, such as the automatic improvement activities credit awarded to groups with clinicians participating in an APM), your MIPS eligible clinicians will receive a neutral payment adjustment for the 2023 MIPS payment year.
- Groups and virtual groups that have submitted data for 2 or 3 performance categories:
- Your MIPS eligible clinicians will receive a MIPS final score and MIPS payment adjustment for the 2023 MIPS payment year.
- You can’t submit an application to override previously submitted data but you can submit an application to request reweighting of performance categories for which you haven’t submitted data.
Official representatives of APM Entities participating in MIPS, including Shared Savings Program ACOs, can submit a MIPS EUC application on behalf of all MIPS eligible clinicians in the APM Entity for the 2021 performance year. If approved, all of the MIPS eligible clinicians in the APM Entity will receive a neutral MIPS payment adjustment in the 2023 MIPS payment year. (Applications must be submitted by an official representative of the APM Entity, and not by a participant in the APM.)
There are some differences from our existing MIPS EUC policy for individuals, groups, and virtual groups:
- APM Entities are required to request reweighting for all performance categories.
- More than 75% of the MIPS eligible clinicians in the APM Entity must be eligible for reweighting in the Promoting Interoperability performance category.
- Unlike MIPS EUC applications for individuals, groups and virtual groups, an APM Entity’s approved application for performance category weighting will override previously submitted data.
- Quality Payment Program COVID-19 Response Factsheet (PDF)
- 2021 MIPS Extreme and Uncontrollable Circumstances Exception Application Guide
- 2021 Data Submission FAQs
- Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.
January 2022
Time Sensitive Alert: Status of Vaccine Mandates
Posted: January 25, 2022
Statement on the Status of the OSHA COVID-19 Vaccination and Testing ETS
Posted January 25, 2022: COVID-19 Vaccination and Testing ETS | Occupational Safety and Health Administration (osha.gov)
The U.S. Department of Labor’s Occupational Safety and Health Administration is withdrawing the vaccination and testing emergency temporary standard issued on Nov. 5, 2021, to protect unvaccinated employees of large employers with 100 or more employees from workplace exposure to coronavirus. The withdrawal is effective January 26, 2022.
Although OSHA is withdrawing the vaccination and testing ETS as an enforceable emergency temporary standard, the agency is not withdrawing the ETS as a proposed rule. The agency is prioritizing its resources to focus on finalizing a permanent COVID-19 Healthcare Standard. OSHA strongly encourages vaccination of workers against the continuing dangers posed by COVID-19 in the workplace.
CMS Vaccination Requirement for Healthcare Workers
While the US Supreme Court struck down OSHA’s COVID-19 vaccination requirement for employers with 100+ employees, the Court ruled that the CMS Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule may be implemented. CMS updated its FAQ document for this rule on January 20, 2022: External FAQ IFC-6 - 1.21.22 (cms.gov)
This document is thorough and should provide answers to most of your questions.
FAQ Highlights
Who must comply?
The vaccination requirement does not apply to Physician Group Practices. It does apply to Ambulatory Surgery Centers enrolled in Medicare and/or Medicaid.
The requirement does not apply to therapy services rendered within a Physician Group Practice.
The requirement does apply to all hospitals enrolled in Medicare and/or Medicaid so those facilities will require all physicians, Physician Assistants and Nurse Practitioners who render services in their facilities to comply even if they are not employed by the facility.
Deadlines
Phase 1 deadline for FL, PA, MD, DE: January 27, 2022
Phase 2 deadline for FL, PA, MD, DE: February 28, 2022
Phase 1 deadline for GA, SC, Kansas, Missouri: February 14, 2022
Phase 2 deadline for GA, SC, Kansas, Missouri: March 15, 2022
Phase 1: Staff must have received at least the first dose of a primary series or a single dose COVID-19 vaccine prior to staff providing any care, treatment, or other services for the facility and/or its patients.
Phase 2: Staff must complete the primary vaccination series (except for those who have been granted exemptions from the COVID-19 vaccine or those staff for whom COVID-19 vaccination must be temporarily delayed, as recommended by CDC).
Boosters:
For the purposes of this Rule, booster doses are not currently needed for staff who have completed a COVID-19 primary vaccination series authorized or licensed by the FDA.
Documentation Plan:
Regulated facilities must implement a process or plan for documenting and tracking staff vaccinations. The Rule does not include testing requirements for unvaccinated staff.
Exemptions:
CMS requires facilities to allow for exemptions to staff with (as a reasonable accommodation for a disability or a sincerely held religious belief, observance, or practice and for medical reasons. Providers and suppliers should establish exceptions as a part of its policies and procedures and in alignment with Federal law… no exemption should be provided to any staff for whom it is not legally required or who requests an exemption solely to evade vaccination. Refer to the Updated CMS FAQ Document for more information: View document
Posted: January 25, 2022
Statement on the Status of the OSHA COVID-19 Vaccination and Testing ETS
Posted January 25, 2022: COVID-19 Vaccination and Testing ETS | Occupational Safety and Health Administration (osha.gov)
The U.S. Department of Labor’s Occupational Safety and Health Administration is withdrawing the vaccination and testing emergency temporary standard issued on Nov. 5, 2021, to protect unvaccinated employees of large employers with 100 or more employees from workplace exposure to coronavirus. The withdrawal is effective January 26, 2022.
Although OSHA is withdrawing the vaccination and testing ETS as an enforceable emergency temporary standard, the agency is not withdrawing the ETS as a proposed rule. The agency is prioritizing its resources to focus on finalizing a permanent COVID-19 Healthcare Standard. OSHA strongly encourages vaccination of workers against the continuing dangers posed by COVID-19 in the workplace.
CMS Vaccination Requirement for Healthcare Workers
While the US Supreme Court struck down OSHA’s COVID-19 vaccination requirement for employers with 100+ employees, the Court ruled that the CMS Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule may be implemented. CMS updated its FAQ document for this rule on January 20, 2022: External FAQ IFC-6 - 1.21.22 (cms.gov)
This document is thorough and should provide answers to most of your questions.
FAQ Highlights
Who must comply?
The vaccination requirement does not apply to Physician Group Practices. It does apply to Ambulatory Surgery Centers enrolled in Medicare and/or Medicaid.
The requirement does not apply to therapy services rendered within a Physician Group Practice.
The requirement does apply to all hospitals enrolled in Medicare and/or Medicaid so those facilities will require all physicians, Physician Assistants and Nurse Practitioners who render services in their facilities to comply even if they are not employed by the facility.
Deadlines
Phase 1 deadline for FL, PA, MD, DE: January 27, 2022
Phase 2 deadline for FL, PA, MD, DE: February 28, 2022
Phase 1 deadline for GA, SC, Kansas, Missouri: February 14, 2022
Phase 2 deadline for GA, SC, Kansas, Missouri: March 15, 2022
Phase 1: Staff must have received at least the first dose of a primary series or a single dose COVID-19 vaccine prior to staff providing any care, treatment, or other services for the facility and/or its patients.
Phase 2: Staff must complete the primary vaccination series (except for those who have been granted exemptions from the COVID-19 vaccine or those staff for whom COVID-19 vaccination must be temporarily delayed, as recommended by CDC).
Boosters:
For the purposes of this Rule, booster doses are not currently needed for staff who have completed a COVID-19 primary vaccination series authorized or licensed by the FDA.
Documentation Plan:
Regulated facilities must implement a process or plan for documenting and tracking staff vaccinations. The Rule does not include testing requirements for unvaccinated staff.
Exemptions:
CMS requires facilities to allow for exemptions to staff with (as a reasonable accommodation for a disability or a sincerely held religious belief, observance, or practice and for medical reasons. Providers and suppliers should establish exceptions as a part of its policies and procedures and in alignment with Federal law… no exemption should be provided to any staff for whom it is not legally required or who requests an exemption solely to evade vaccination. Refer to the Updated CMS FAQ Document for more information: View document
