By Lauren Flynn Kelly
As efforts to contain the outbreak of COVID-19 continue to evolve, the Trump administration on March 30 issued a series of new flexibilities aimed at increasing hospital and provider capacity. At the same time, CMS in a March 30 memo provided some respite to Medicare Advantage and Part D plans dealing with the crisis by suspending audit and quality reporting activities so that plans and states can focus on providing care to the increasing number of beneficiaries affected by the new coronavirus.
As physicians cater to patients who are or may be infected with COVID-19, and as the federal government advises adults to delay elective surgeries and nonessential procedures during the outbreak, plans are likely to face issues with reporting quality data used to determine future star ratings.
CMS in an interim final rule issued March 30 said it will allow for several key changes to the calculations for the 2021 and 2022 Parts C and D star ratings to account for the expected impact of the public health emergency on data collection and performance.
Up until this point, the potential impact of COVID-19 on CMS’s quality agenda and more specifically quality-based payments to MA plans was a major area of uncertainty for insurers, points out Dan Mendelson, founder of Avalere Health. “The MA quality payment system is based largely on visits that are not possible in a world where COVID-19 has changed the face of American health care, so this program needs to be fundamentally modified for 2021,” says Mendelson. “It appears that CMS still intends to use star ratings, albeit a very different version that relies largely on historical data — which will advantage plans that had a strong prior year.”
But in addition to the interim final rule, more guidance may be needed on the potential impact of COVID-19 on MA payment rates for 2021. And the most important additional guidance that the industry needs, Mendelson says, is for CMS “to allow for telehealth visits to fully substitute for face-to-face visits during this critical and uncertain period of time.”