August 2019
Federal CMS releases 1,700-page proposed rule for the 2020 Medicare physician fee schedule
On July 29, the Centers for Medicare and Medicaid Services released a proposed rule for the 2020 Medicare Physician Fee Schedule (PFS) and Quality Payment Program (QPP). The rule covers many topics including a new participation framework in the Merit-based Incentive Payment System (MIPS) and new payments for managing patients with opioid use disorder. One piece of good news is that the federal CMS accepted the recommendations from the American Medical Association and RVS Update Committee (RUC) and will not collapse the evaluation and management (E/M) levels with a blended payment rate as previously proposed. Read more here.
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DOI issues cease and desist orders for Trinity Healthshare and Aliera Healthcare
The Colorado Division of Insurance issued cease and desist orders for Trinity Healthshare and Aliera Healthcare on Aug. 12. Trinity represents itself as a health care sharing ministry. Aliera is the administrator, marketer and program manager for Trinity. According to a DOI news release, the division is concerned that they may be using misleading marketing practices, blurring the lines between health insurance that complies with the requirements of the Affordable Care Act and non-compliant insurance (like what is offered by health care sharing ministries). Because of this, the DOI says, the companies may be putting consumers at risk and violating Colorado insurance law. Read more here.
COQPP Coalition presents August Fast Facts to aid you in your QPP journey
The Colorado QPP Coalition presents its August Fast Facts, the latest information on the Quality Payment Program and more that takes just five minutes to read. Check it out here for more on the following topics:

  • The QPP Performance Year 2020 Proposed Rule is now available
  • How do I comment on the CY 2020 proposed rule?
  • MIPS data validation and audit
  • What is the 2019 Complex Patient Bonus?
  • Reminder: Targeted reviews MUST be submitted by Sept. 30, 2019
  • Upcoming events!
  • New QPP resources released!
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Federal CMS provides information on phase I and II operating rules for the HIPAA eligibility and benefits transaction
The federal CMS has provided information on the operating rules for adopted HIPAA transactions, highlighting phase I and phase II operating rules for the eligibility and benefits inquiry. An eligibility and benefits transaction covers inquiries and responses about a patient’s eligibility for insurance benefits, including information like co-pays and deductibles. The phase I and phase II operating rules for the eligibility for a health plan and health care claim status transactions were adopted in December 2011 through interim final rulemaking (CMS-0032-IFC) and became required for use on Jan. 1, 2013. All HIPAA-covered entities must comply with these operating rules. Read more here.
Register for a TMF webinar about MIPS participation if you use a paper system - Aug. 28
The TMF Quality Innovation Network will hold virtual office hours on Wednesday, Aug. 28 at 11 a.m. MT to discuss how to participate in MIPS without an EHR. Many small practices do not use electronic health records and instead maintain patient records on paper. Even those using paper records can participate in the Merit-based Incentive Payment System (MIPS) and perform well! In this webinar, TMF consultants will provide insight into tools that will improve practices' MIPS performance. Register here.
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Take Credit Cards? Is Your Practice Ready for the Oct. 15 EMV Deadline?

Important! What your practice needs to know about switching to EMV: Click here.
New Medicare card: Transition period ends in less than five months
Starting Jan. 1, 2020, all providers must use the Medicare Beneficiary Identifier (MBI). The Centers for Medicare and Medicaid Services will reject claims submitted with the Health Insurance Claim Number (HICN) with a few exceptions, and reject all eligibility transactions.

Many providers are using the MBI for Medicare transactions. For the week ending Aug. 2, providers submitted 77 percent of fee-for-service claims with the MBI. Protect patients’ identities by using MBIs now for all Medicare transactions.

Don’t have an MBI?

  • Ask your patients for their card. If they did not get a new card, give them the Get Your New Medicare Card flyer in English or Spanish.
  • Use your Medicare Administrative Contractor’s look up tool. Sign up for the Portal to use the tool.
  • Check the remittance advice. We return the MBI on the remittance advice for every claim with a valid and active HICN.

For more information, see the MLN Matters Article.
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FAQ: How CO APCD data will support out-of-network bill implementation
The Colorado General Assembly passed HB 19-1174 during the 2019 legislative session to help protect patients from surprise out-of-network bills. Included in the bill are specifications regarding provider reimbursements for out-of-network emergency and non-emergency visits. The Colorado All Payer Claims Database is identified in the bill as a data source related specifically to the statewide commercial carrier median geographic payments specified in the bill, and CIVHC is working collaboratively with the Division of Insurance to finalize specifics regarding the methodology that will be used and the data elements that will be available to the DOI from the CO APCD. As they're working through the details, CIVHC has compiled a "frequently asked questions" document to provide some guidance to providers. Access the FAQ here.
Access COPIC's resources on Colorado Candor Act
The recently passed Colorado Candor Act is a bipartisan effort that establishes a voluntary framework for health care providers and facilities to offer compassionate, honest, timely and thorough responses to patients who experience an adverse health care incident. It is designed to benefit patients, their families, clinicians, and health care systems by formalizing a non-adversarial process where there can be open communication about what happened, why it happened, and what can be done to prevent this in the future. COPIC has made available several resources that provide details about the act, the Candor process and sample templates of required forms.  Access the resources here.
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