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July 9, 2020

COVID-19 Financial Relief: Molina Primary Care Support; Medicaid Funding Concerns; MIPS Opt-out; More

An update on financial relief measures for physicians and practices experiencing lost revenues or increased expenses due to COVID-19.

Molina announces $10 million for primary care support

One of the issues that the WSMA has prioritized during the pandemic is securing financial support for physician practices, virtually all of which have seen declining patient volumes and revenue in recent months. One of the tracks of discussion has been with our state's Health Care Authority and the managed care organizations that contract with the Medicaid program. We were pleased to see Molina announce that they will be providing $10 million to primary care providers they contract with, in addition to $5 million for substance use disorder providers.

According to Molina, the payments will be delivered automatically to all contracted primary care providers who are not on total capitation payments - providers do not need to do anything to trigger these payments. Molina has stressed that the disbursement is not an advance or a loan to primary care providers, but are "supplemental, direct payments for primary care services that are delivered." It will be paid to Molina's primary care providers as a one-time payment (supplemental care coordination fee) during the month of July.

The WSMA applauds Molina for making this investment in the primary care system, as it's imperative to take steps to support the financial viability of practices so that the many new enrollees of the Medicaid system will have adequate access to care. We encourage the state's other MCOs to take similar action in making significant, supplemental, directed payments (not just loans or advances) to providers across the state.

HHS will renew public health emergency

Last week, the U.S. Department of Health and Human Services indicated it will extend the COVID-19 public health emergency that is set to expire July 25. The extension would prolong the emergency designation by 90 days. As noted by WSMA CEO Jennifer Hanscom in Weekly Rounds, this is welcome news for physicians. Several payment policies and regulatory adjustments are attached to the public health emergency, including the Medicare inpatient 20% add-on payment for COVID-19 patients, increased federal Medicaid matching rates, requirements that insurers cover COVID-19 testing without cost-sharing, and waivers of telehealth restrictions.

$15 billion is being distributed to Medicaid providers by HHS. Has your practice received its share?

The federal CARES Act appropriated $175 billion to physicians, providers, and health care facilities through a variety of mechanisms. The most recent distribution that was announced by the Department of Health and Human Services is $15 billion dedicated for eligible physicians and providers who participate in Medicaid and the Children's Health Insurance Program.

To be eligible for this funding, clinicians must have billed their state's Medicaid/CHIP programs or Medicaid managed care plans between Jan. 1, 2018 and Dec. 31, 2019. Additionally, they must not have received payments from the earlier $50 billion Provider Relief Fund general distribution based on Medicare utilization.

Washington state's Medicaid agency, the Health Care Authority, has raised concerns with HHS about the Medicaid distribution, asserting the funds allotted are insufficient and that it's administratively burdensome for practices to tap into. Perhaps most concerningly, practices were not aware that accepting the Medicare general distribution would preclude them from receiving Medicaid funds, where the latter may have been financially advantageous for a practice. Further, there is no mechanism for a practice to return the Medicare funds to create eligibility for the Medicaid distribution.

If you believe you're eligible for a payment under the Medicaid distribution, HHS provides an Enhanced Provider Relief Fund Payment Portal that allows you to report your annual patient revenue, as well as information such as the number of Medicaid patients you serve, which will be used as factors in determining your payment. Distributions to eligible providers will equal to at least 2% of reported gross revenues from patient care.

If you have concerns pertaining to the Medicaid distribution or anything related to the Provider Relief Fund under the CARES Act, the WSMA wants to know. Share your perspective with us by emailing policy@wsma.org.

Find more information on financial relief measures for physicians and practices in our COVID-19 Resources webpages.

Manual opt-out option for the MIPS program

The Centers for Medicare & Medicaid Services announced that physicians will have the option to opt out completely or partially from the 2020 MIPS program by completing a hardship exemption application and indicating it is due to the COVID-19 Public Health Emergency. Individual clinicians and group practices have until Dec. 31, 2020 to complete the hardship application.

CMS plans on providing physicians with a couple of options on the hardship exemption application. For example, a practice may submit a hardship application and indicate that they do not want to be scored on Cost and Quality and have their score calculated only based on Promoting Interoperability and Improvement Activities. Alternatively, practices may submit a hardship application and opt out of all four performance categories and be held harmless from a 2022 payment adjustment. Submitting any MIPS data to CMS will override the hardship exception application and physicians will be scored on their submission.

The Quality Payment Program website is in the process of being updated with the 2020 policy and should reflect the announcement along with additional educational materials in a couple weeks. The information currently posted on the website is regarding the 2019 MIPS COVID-19 policy. CMS has also indicated that additional information on MIPS COVID-19 policy will be included in upcoming rulemaking.

Updated Provider Relief Fund FAQs

The Department of Health and Human Services has issued updated Provider Relief Fund FAQs. Of note, the new FAQs clarify whether there is a set period of time in which providers must use the funds to cover eligible expenses or lost revenues attributable to COVID-19. Consistent with previous guidance, HHS indicated that it expects providers to "only use Provider Relief Fund payments for as long as they have eligible expenses or lost revenue," adding that, "if, at the conclusion of the pandemic, providers have leftover Provider Relief Fund money that they cannot expend on permissible expenses or losses, then they will return this money to HHS." HHS will provide future instructions.

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