Zotec Partners Anesthesiology Digest | January 22, 2021

January 23, 2021

Radiology Digest: News from the week of January 22, 2021.

ASA Applauds HHS Decisions to Expand Access to Opioid Use Disorder Treatment

January 18, 2021 | Included in Radiology Digest – January 22, 2021

On Jan. 14, the U.S. Department of Health and Human Services (HHS) announced it is releasing updated practice guidelines to expand access to medication-assisted treatment (MAT) by allowing physicians to prescribe buprenorphine for opioid use disorder (OUD) without certain certification requirements for an x-waiver. This exemption applies only to physicians, not all “qualifying practitioners” defined under the Controlled Substances Act (CSA). ASA supports this decision by HHS and believes it will allow patients to have improved access to treatment for opioid use disorder.

ASA supports the removal of barriers, such as the x-waiver, that discourage physicians from being certified to prescribe buprenorphine; physicians having the appropriate authority to treat patients with opioid use disorder is critical to ending the opioid epidemic.

The 12-month period ending in June 2020 saw the highest number of overdose deaths ever recorded in a 12-month period, and an increase of over 21% compared to the previous year. The increase in overdose deaths within the United States highlights the need for treatment services to be more widely accessible for individuals most at risk of an overdose. Without MAT, the possibility of a person relapsing is significant.

ASA applauds HHS for removing these barriers for physicians treating patients with opioid use disorder. To read more, go to ASA’s website.

CMS Approves Rule Forcing Insurers to Ease Prior Authorization 

By Michael Brady | January 15, 2021 | Included in Radiology Digest – January 22, 2021

CMS on Friday, January 15, approved its plan to streamline prior authorization and improve patient and provider access to medical records.

The final rule requires payers—including Medicaid, the Children’s Health Insurance Program and exchange plans—to build application program interfaces to support data exchange and prior authorization. CMS said the changes would allow providers to know in advance what documentation each payer would require, streamline documentation processes and make it easier for providers to send and receive prior authorization information requests and responses electronically.

“The requirements of this rule specify that each of these payers will build an API-enabled documentation requirements look-up service and make these public so providers can access documentation and prior authorization requirements from their EHR platforms. Once a provider knows what is required for each prior authorization, the next step is submitting it electronically,” the agency said in a statement.

Under the rule, Medicaid and CHIP fee-for-service and managed-care plans will have up to 72 hours to make prior authorization decisions on urgent requests and seven calendar days for non-urgent requests. All covered payers must provide a specific reason for any denial.

The changes will phase in from 2023 through 2024.

Healthcare groups criticized CMS for giving them just a few weeks to review and comment on the proposed rule and excluding Medicare Advantage plans from the requirements. To read more, go to Modern Healthcare.

ASA Response to CMS MIPS Value Pathways (MVP) Town Hall

January 14, 2021 | Included in Radiology Digest – January 22, 2021

The American Society of Anesthesiologists submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) following the Merit-based Incentive Programs (MIPS) Value Pathways (MVPs) Town Hall session held on January 7, 2021. During this Town Hall CMS solicited comments from attendees regarding the MVP subgroup reporting implementation, MVP design and MVP reporting requirements and scoring.

ASA’s response focused primarily on:

• Urging CMS to reconsider the subgroup reporting mechanism and develop a process that both encourages MVP reporting and reduced group reporting burden. With the additional information provided leading up to this Town Hall, the implementation of subgroup reporting as-is would lead to increased burden on practices who may be required to report both traditional MIPS and via subgroup reporting.

• ASA supported the continuation of non-patient facing exemptions for MVPs. This will allow physician anesthesiologists to participate without the potential repercussions of being scored on a performance category that would not otherwise apply.

• ASA supported and encouraged CMS to consider incentives such as awarding additional MIPS points and/or preferential scoring to encourage MVP use by practices. However, CMS should test and publish different scoring methods to ensure a sense of fairness and accuracy in how ECs and groups are assessed.

ASA will continue the conversation with CMS to support a collaborative approach to the implementation of MVPs for the 2022 Performance Year.

For additional information on MVPs and a link to all topics covered during the Town Hall please visit the Quality Payment Program Resource Library.

New Rule Makes It Harder for HHS to Penalize Guidance Violations

By Michael Brady | January 12, 2021 | Included in Radiology Digest – January 22, 2021

HHS officials bolstered President Donald Trump’s deregulation agenda on Tuesday, signing
off on a rule that makes it more difficult for regulators to go after individuals and
organizations for not following standards laid out in guidance documents.

The rule effectively bans the department from penalizing individuals and organizations for
noncompliance with a standard or practice if HHS only announced it in a guidance document.
It also lays out a substantial process HHS must follow to carry out civil enforcement
for potential violations. HHS said the rule is necessary to ensure fairness.

“HHS can only apply standards or practices that have been publicly stated in a manner that
would not cause unfair surprise,” according to a department statement.

In addition, HHS can only carry out civil administrative inspections if the department’s
inspection process is publicly available.

“Whenever HHS relies on a document arising out of litigation to establish jurisdiction in
future civil enforcement actions, HHS must publish that document and an explanation of the
document’s jurisdictional implications,” the department said in a statement.

The rule also requires HHS to provide individuals and organizations with written notice of a
guidance violation and a chance to respond before pursuing legal action.

“A cornerstone of fair governance is transparency—regulated parties need to know in
advance the standards by which the government will judge their conduct,” HHS Chief of Staff
Brian Harrison said in a statement.

The rule takes effect immediately.

To read more, go to Modern Healthcare.

Updated Medicare Conversion Factors Announced

January 12, 2021 | Included in Radiology Digest – January 22, 2021

The revised Medicare Conversion Factors (CF) have been posted. These new figures reflect
the impact of the Consolidated Appropriations Act of 2021 and override the figures that were
listed in the CY 2021 Final Rule.

The Medicare Anesthesia CF will be $21.5600 instead of $ 20.0547 as previously
announced. The locale specific CFs are available here. The RBRVS CF will be $34.89 instead of

ASA anticipates that the Medicare Administrative Contractors (MAC) will update their files
and post information on their websites about when they will be ready to process claims with
these new CFs.

To read more, go to ASA’s website.

CMS Recalculates Medicare Physician Fee Schedule Rates for 2021

By Jacqueline LaPointe | January 11, 2021 | Included in Radiology Digest – January 22, 2021

CMS has updated Medicare Physician Fee Schedule rates for 2021 after a COVID-19 stimulus
package mitigated budget neutrality cuts finalized in a December rule.

The Consolidated Appropriations Act, 2021 passed by Congress on Dec. 21, 2020, enacted a
3.75 percent increase in Physician Fee Schedule payments for all providers in 2021 to
“support physicians and other professionals in adjusting to changes in payment for
physicians’ services during 2021.”

The $1.4 trillion COVID-19 stimulus package also suspended payments for Healthcare
Common Procedure Coding System (HCPCS) code G2211 for three years, which also impacted
the budget neutrality requirement for the Physician Fee Schedule.

G2211, an add-on code for the complexity inherent to evaluation and management (E/M)
visits, accounted for about $3 billion, or three percent, of spending in the Medicare Physician
Fee Schedule, according to the American Medical Association (AMA).

The delay in implementing the code will reduce the budget-neutrality adjustment, and as a
result, some specialists will no longer face significant rate cuts as laid out in the 2021
Medicare Physician Fee Schedule final rule, the Association said.

The rule finalized cuts of up to 10.2 percent for certain specialties and services because of a
budget neutrality requirement that forces any significant increases in Physician Fee Schedule
payments to be offset in other areas.

CMS had decided in the final rule to boost rates for E/M services that support primary care
and chronic disease management, which triggered the budget-neutrality adjustment factor
for 2021.

The agency reported that the final rule decreased the Physician Fee Schedule conversion
factor by $3.68 to $32.41 to reflect a statutory update of 0.00 percent and the adjustment to
account for changes in relative value units and expenditures that would result from finalized

“This finalized policy marks the most significant updates to E/M codes in 30 years, reducing
burden on doctors imposed by the coding system and rewarding time spent evaluating and managing their patients’ care,” CMS Administrator Verma said at the time. “In the past, the
system has rewarded interventions and procedures over time spent with patients – time
taken preventing disease and managing chronic illnesses.”

Specialty providers have opposed the rate cuts, which would have disproportionately
impacted certain specialties and services during the COVID-19 pandemic.

To read more, go to Revcycle Intelligence.

Thousands Comment in Support of Maintaining Medicare Physician Supervision

January 6, 2021 | Included in Radiology Digest – January 22, 2021

With outstanding support from the community, nearly 5,000 comments were posted to the
Federal Register over a 30-day comment period in support of maintaining physician-led
anesthesia care for seniors and those with disabilities. The Federal Register notice issued by
HHS “Regulatory Relief To Support Economic Recovery; Request for Information (RFI)”
generated a total of over 6,000 comments total before the comment period concluded on
December 28. The American Society of Anesthesiologists (ASA) applauds its members and
the public for standing up for patient safety for Medicare patients.

Earlier this year, in an effort to respond to the COVID-19 pandemic, the Centers for Medicare
and Medicaid Services (CMS) issued a variety of temporary waivers to existing Medicare
rules. The action effectively ended enforcement of many Medicare regulations for the period
of the Public Health Emergency. The Medicare requirement for physician supervision of
anesthesia care was among the rules that were temporarily waived. In November, HHS
issued a “request for information” seeking public comment on whether any of the waived
rules, including the Medicare supervision rule, should be made permanent. ASA strongly
believes that making this Medicare waiver permanent would put the lives of seniors and
those with disabilities at risk.

During the comment period, over 1,000 Medicare beneficiaries and their concerned family
members submitted comments in support of high-quality, physician-led anesthesia care. ASA
remains hopeful that given this strong and overwhelming response, CMS will end the
temporary waiver, and resume the safe, high-quality, physician-led anesthesia care for
Medicare patients.

In formal comments, ASA urged HHS to “continue to recognize the physician delivered and
the physician supervised team-based model of anesthesia as the safe and appropriate
standards of care for Medicare and Medicaid patients requiring anesthesia services.” In
additional supplemental formal comments submitted by ASA, a variety of other waivers were
reviewed in relation to patient care. ASA will continue to work with Administration officials in
support of patient safety and high-quality care.

To read more, go to ASA’s website.

Indiana Taps Zotec for Statewide COVID-19 Vaccine Management System

Katie Adams | January 11, 2021 | Included in Radiology Digest – January 22, 2021

The Indiana Department of Health partnered with Zotec Partners to deploy a statewide
COVID-19 vaccine information management system, the healthcare revenue cycle
management company announced Jan. 11.

Zotec Partners’ platform alerts eligible vaccine recipients via text reminders, helps recipients
schedule appointments for their first and second dose, tracks vaccine inventory status and
determines which areas of the state are most in need of vaccines.

Hoosiers have already scheduled more than 460,000 COVID-19 vaccination appointments
using the system, and the state plans to use the platform to schedule 300,000 more
appointments by the end of January.

Zotec began working with Indiana’s health department in April by providing IT support for
COVID-19 testing.

To read more, go to Becker’s Hospital Review.

HHS Extends COVID-19 Public Health Emergency Through Spring

By Rachel Cohrs | January 8, 2021 | Included in Radiology Digest – January 22, 2021

HHS on Thursday extended its COVID-19 public health emergency declaration, which is
attached to increased funding for healthcare providers and regulatory flexibilities.

The declaration was set to expire on Jan. 20, the day when President-elect Biden is scheduled
to be inaugurated. The renewal takes effect on Jan. 21 and extends for 90 days. The renewal
eliminates the risk of a lapse as the new administration takes over.

“Our work to combat the virus will continue, as will our work to ensure a peaceful and
orderly transition,” HHS Secretary Alex Azar said in a tweet announcing the renewal.

Significant anxiety swirled around whether the Trump administration would renew the
declaration in summer 2020, but public health experts expect the Biden administration to be
more aggressive with the federal COVID-19 response and more likely to continue renewing
the designation.

Some notable policies tied to the public health emergency are the Medicare inpatient 20%
add-on payment for COVID-19 patients, increased federal Medicaid matching rates and
maintenance of effort requirements, requirements that insurers cover COVID-19 testing
without cost-sharing and waivers of telehealth restrictions.

Adjustments CMS made to the Medicare Shared Savings Program for accountable care
organizations are also connected to the length of the public health emergency. The number
of months the emergency lasts affects the amount of shared losses an ACO must pay back to

Congress also conditioned increased Medicaid funds on states covering vaccines without
cost-sharing for enrollees, but that requirement expires with the public health emergency.

To read more, go to Modern Healthcare.

‘Payviders,’ Burnout and COVID-19 are among the threats to a better year for hospitals in

By Tara Bannow | January 2, 2021 | Included in Radiology Digest – January 22, 2021

Among the many looming threats hospitals will face in 2021 is the rise of so-called
payviders—insurers that have bought or partnered with medical groups and other providers.

“The line between providers and payers is getting blurrier and blurrier over the course of
time with major payers taking significant positions in the provider space,” said David
Morlock, a managing director in Cain Brothers’ Health Systems M&A group.

Such deals exploded in 2020, a trend that will likely continue this year. That doesn’t bode
well for hospitals, as these deals usually entail managing patients’ cost using global budgets.
That means keeping them out of the most expensive settings—namely, anything involving a

The 2021 financial outlook for healthcare providers is more difficult to predict than ever, as
so much of it depends on the trajectory of an out-of-control pandemic.

While many had expected the crisis that began in earnest in March 2020 to be contained by
year’s end, it’s clearly far from over.

“It’ll be more of a two-year event,” said Megan Neuburger, a managing director with Fitch
Ratings. Neuburger studies investor-owned hospitals, and she’s not forecasting a complete
earnings recovery for them until 2022.

COVID-19 vaccines carry promise, but the rollout will take months and it remains unclear how
many Americans will get vaccinated. In the meantime, cases and deaths continue to climb,
underscoring the urgency of the undertaking.

Still, experts who follow the industry say they foresee some intriguing trends playing out this
year, one involving a specific area of outsourcing. But the hard truths of lower patient
revenue and higher expenses aren’t going anywhere in the near term.

To read more, go to Modern Healthcare.

Learn more about what Zotec Partners can do for your radiology practice here.