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June 2022 Medicare Education Resources, COVID-19 Updates & Other Medicare Updates

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Wednesday, June 22, 2022

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Medicare Educational Resources

MLN Fact Sheet: Complying with Outpatient Rehabilitation Therapy Documentation Requirements

This MLN Fact Sheet was update in May 2022 (link) to add information about the 2 new therapy assistant service modifiers created by CMS. This Fact Sheet is intended to help providers learn to avoid common billing errors when submitting therapy claims to Medicare.

COVID-19 Updates

June 7, 2022: AAPM&R Long COVID Cardiovascular Complications Guidance Statement

The American Academy of Physical Medicine and Rehabilitation (AAPM&R) announced (link) new guidance for diagnosing and treating cardiovascular complications. They estimate that eight to twenty-five million Americans have or have had symptoms of Long COVID and that cardiovascular complications are common. The Guidance officially titled the Multi-Disciplinary Collaborative Consensus Guidance Statements on the Assessment and Treatment of Cardiovascular Complications in Patients with Post-Acute Sequelae of SARS-CoV-2 Infection (PASC) (link), includes recommendations for the assessment and treatment of patients with PASC cardiovascular complications,

June 14, 2022: Surveys for Compliance with Vaccination Requirements Memorandum (QSO-22-17-ALL)

CMS released this memorandum (link) to notify providers of a change in surveys for compliance with Omnibus COVID-19 health care staff vaccination requirements. Per the memorandum summary:

  • Survey oversight of the staff vaccination requirement for Medicare and Medicaid certified providers and suppliers will continue to be performed during initial and recertification surveys but will now only be performed in response to complaints alleging non-compliance with this requirement, not all surveys. Under prior guidance, all surveys included oversight of the staff vaccination requirement, and
  • CMS will revise QSO 22-11 to ensure deficiency determinations reflect good faith efforts implemented by providers and suppliers and incorporate harm or potential harm to patients and residents resulting from any non-compliance.
June 17, 2022: FDA COVID-19 Vaccine Authorization for Children Down to 6 Months of Age

The FDA announced (link) their authorization for the use of the Moderna and Pfizer-BioNTech COVID-19 vaccines for children down to 6 months of age. This announcement includes information about vaccine effectiveness and safety.

Other Updates

CMS Posts First Two Price Transparency Enforcement Actions

CMS has posted (link) civil monetary penalty (CMP) notices for the first two hospitals for not fully implementing the price transparency requirements. In both instances the hospitals did not respond to the request for a Corrective Action Plan (CAP). The CMS letters includes details of specific violations.

June 14, 2022: AHA Letter to Congress Urging Action to Stop July 1, 2022, Sequester Cuts

As part of the CARES Act in 2020, sequestration was suspended through December 31, 2020. The 2% cut was ultimately suspended through March 31st of this year. The December 10, 2021, Protecting Medicare and American Farmers from Sequester Cuts Act enacted phasing back in the cuts with a 1% payment adjustment effective April 1, 2022, and planned return to the full 2% cut effective July 1, 2022.

On June 14th, the American Hospital Association (AHA) submitted a letter to Congress (link) urging action to prevent the 2% cut scheduled to go in effect on July 1st. The letter ends by noting that “without immediate action, the AHA estimates hospitals will lose at least $3 billion by the end of the year. These further Medicare payment cuts threaten access to care for patients and communities.”

June 15, 2022: Supreme Court Rules in Favor of Hospitals over 340B Medicare Reimbursement Cuts

In a unanimous decision (link), the Supreme Court ruled that the decision to reduce reimbursement rates to hospitals participating in the 340B program was unlawful.

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This material was compiled to share information.  MMP, Inc. is not offering legal advice. Every reasonable effort has been taken to ensure the information is accurate and useful.