COVID-19 & Policy Changes

May 7, 2020 Ellen Harrison

Updated Medicare Payment & Quality Program Requirements

As the COVID-19 pandemic rages on, everyone is watching the American healthcare system. To ease some burden on clinicians and healthcare organizations, the U.S. Centers for Medicare and Medicaid Services (CMS) has taken steps to change regulations related to Medicare payments and quality reporting programs. Changes relative to gathering data from 2019 as well reporting on that information, have been implemented across the continuum of care. They encompass programs targeted at clinicians, hospitals, post-acute care providers, and home healthcare providers.

CMS Changes Affecting Provider Payment & Reporting

The Merit Based Incentive Payment System (MIPS) is one of the tracks under the Quality Payment Program, intended to move Medicare Part B providers towards value based (performance based) payment systems.

CMS has recognized that capturing and reporting data at this time is challenging, as resources are diverted towards the COVID-19 crisis. As a result, the data submission deadline for MIPS has been extended by 30 days to April 30, 2020. If MIPS eligible clinicians fail to submit MIPS data by the April 2020 deadline, the MIPS Automatic Extreme and Uncontrollable Circumstances Policy will apply.

No additional action is needed to qualify for the automatic extreme and uncontrollable circumstances policy. Clinicians will be automatically identified and will receive a neutral payment adjustment for the 2021 MIPS payment year.

MIPS eligible clinicians who submit data by April 30, 2020 on two or more performance categories will be scored on those categories and receive a 2021 MIPS payment adjustment based on their 2019 MIPS final score.

According to Advisory Board, the deadline for MSSP ACOs to report 2019 data has also been extended to April 30, 2020, from its original deadline of March 31.

For more detailed information and FAQs related to MIPS changes, download CMS’s Fact Sheet.

Medicare Advantage and Part D: 2021 Star Ratings Data Collection

At the end of March, CMS implemented additional flexibilities for Medicare Advantage and Part D plans as part of its fight against COVID-19. These include guidelines for 2021 Star Ratings Data Collection. Highlights include:

  • Healthcare Effectiveness Data and Information Set (HEDIS) 2020 Data. CMS has eliminated the requirement for Medicare health plans to submit HEDIS 2020 data covering the 2019 measurement year for the Medicare program. Any HEDIS data that has been collected can be used, however, for internal quality improvement efforts.
What does this mean for health plans?


It may make sense to pause condition management and adult preventive for Medicare members unless telehealth capabilities are available. For Medicaid members, however, HEDIS-related “chart chase” activities should continue. For all members, it will also be important to continue to discuss year-end gap closure.

  • 2020 Consumer Assessment of Healthcare Providers & Systems (CAHPS) Survey. CMS has eliminated the requirement to submit 2020 CAHPS Survey data for Medicare health and drug plans (Medicare Advantage and Part D).
What does this mean for health plans?


Medicare Advantage and Part D plans can use any CAHPS data collected for internal quality improvement programs. Surveys will continue, however for Medicaid members for Q3 2020 through Q1 2021. Plans may also want to conduct an informal CAHPS survey to take the pulse of consumer satisfaction and access. This type of informal survey also represents an opportunity to gather additional insights into other consumer issues related to COVID-19, social distancing, deferred care, and more.

  • Medicare Health Outcomes Survey (HOS). This year’s survey, which was scheduled for April through July 2020, has been postponed to late summer. CMS is continuing to monitor the situation to see if further adjustments are needed. Additional information will be provided in the coming months.
What does this mean for health plans?


Health plans are in a “wait and see” time for HOS, since the survey may or may not be fielded in 2020. However, health plans should continue to monitor and support key health outcomes for Medicare members.

  • 2021 Star Ratings Calculations. CMS will use last year’s HEDIS measure scores and ratings from 2020 Star Ratings (based on care delivered in 2018) for the 2021 Star Ratings. CAHPS measure data scores and ratings from the 2020 measure-level Star Ratings will be used for 2021 Star Ratings.
  • 2022 Star Ratings Calculations. CMS expects Medicare Advantage contracts to submit HEDIS data in June 2021. Medicare Advantage and Part D Plan contracts are expected to administer the CAHPS survey in 2021 as usual. To address concerns about overall performance in 2020, CMS has changed the applicability date of the guardrails policy from January 1, 2020 to January 1, 2021. It has also delayed implementation of the 5-percentage point cap. Cut points for the 2022 Star Ratings can change by more than 5 percentage points if national performance declines overall as a result of the outbreak. Part C and Part D improvement measure scores for the 2022 Star Ratings will be calculated as codified, but the “hold harmless rule” has been expanded to include all contracts at the overall and summary rating levels. This has been done in response to potential declines in industry performance due to the pandemic.
What do changes to the Star Ratings calculations mean for health plans?


Even in the time of COVID-19, plans must encourage preventive and chronic care. Whenever possible, plans should promote telehealth for preventive and chronic care visits, and prioritize the riskiest members for care once offices re-open.

Accelerated and Advanced Medicare Payments

CMS’s Accelerated Payment Program has been paused. On April 26, 2020, CMS announced that it is reevaluating the amounts that will be paid under its Accelerated Payment Program and suspending its Advance Payment Program to Part B suppliers effective immediately.

Beginning on April 26, 2020, CMS will not be accepting any new applications for the Advance Payment Program and CMS will be reevaluating all pending and new applications for Accelerated Payments in light of historical direct payments made available through HHS’s Provider Relief Fund. Significant additional funding will continue to be available to hospitals and other healthcare providers through other programs.

For more information on the CARES Act Provider Relief Fund and how to apply, visit

CMS Changes Affecting Accountable Care Organizations (ACOs)

In light of the pandemic, CMS is modifying the financial methodology used to account for COVID-19 costs. This will help ensure that ACOs are treated fairly, no matter how their patient populations are affected by the coronavirus.

In addition, CMS has canceled the annual application cycle for 2021. If an ACO’s participation is scheduled to end this year, it will be given the option to extend for another year. If an ACO is required to increase its financial risk during their current agreement period in the program, it will have the option to stay in its current risk level for the next year.

For states that operate a Basic Health Program, CMS is allowing them to submit revised BHP Blueprints for temporary changes linked to COVID-19 that aren’t restrictive and could be effective retroactively to the first day of the COVID-19 public health emergency declaration.


These modifications to CMS reporting and payment practices will give heavily burdened healthcare organizations and clinicians a bit more breathing room to manage during this incredibly difficult time. As the COVID-19 pandemic progresses in the weeks and months, additional information and modifications may be forthcoming.

We can’t forget, however, that these changes will have an impact on the future of quality initiatives, quality improvement, and care management. In future posts, we’ll consider these issues, as well as what steps can be taken now to minimize adverse effects in the future. For now, be safe and be well.


 For more information about how HMS can quickly deploy a coronavirus-specific rapid messaging program, check out our solution overview.

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