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MGMA COVID-19 Action Center

Insight Article

Disaster Planning

Policies & Procedures

Medicare Payment Policies

As the country works to combat the spread of Coronavirus Disease 2019 (COVID-19), MGMA will keep medical group practices apprised of the latest regulatory and legislative developments that could affect patient care and practice operations. MGMA’s COVID-19 Action Center is routinely updated as new information is made available.

Navigate to the major issue areas impacting medical groups:

Financial and Employment Assistance Programs
Telehealth, Telemedicine and Other Regulatory Waivers
MGMA Advocacy and Other Resources

Financial and Employment Assistance Programs

For practices with fewer than 500 employees*

Click here for a comprehensive MGMA analysis.
Click here for the SBA Paycheck Protection Program FAQs.

*Due to the passage of Paycheck Protection Program and Health Care Enhancement Act into law, effective April 27, 2020 at 10:30 AM EDT, the SBA will resume accepting PPP loan applications from approved lenders on behalf of any eligible borrower.

For practices of all sizes 

Click here for a comprehensive MGMA analysis.

The Attestation Portal for the initial $30 billion general distribution from the Department of Health & Human Services (HHS) is now open. Providers that received a payment from HHS as part of the Provider Relief Fund authorized under the CARES Act must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions within 30 days of receiving payment. Group practices with questions about the grant funds can call the Provider Relief hotline at (866) 569-3522.

The General Distribution Portal for the latest $20 billion from HHS is now open. Providers who have already received payments from the CARES Act Provider Relief Fund must attest to each payment associated with their billing Taxpayer Identification Number(s). In addition, providers who have already received payments will need to upload their most recent IRS tax filings as well as estimates of lost revenues for March and April 2020.
Click here for a matrix of federal COVID-19 financial assistance programs.

Employment Provisions

Click here for a comprehensive MGMA analysis.

Telehealth, Telemedicine, and Other Regulatory Waivers


Click here for a comprehensive MGMA analysis.

HHS has instituted several flexibilities that waive many of the generally applicable rules governing Medicare telehealth and telemedicine services in response to the COVID-19 public health crisis. These include removing billing limitations and expanding the number of approved covered codes for Medicare telehealth and new reimbursements for audio-only Evaluation & Management services. 

Provider Enrollment

The following provider enrollment flexibilities are implemented: 
  • Temporarily suspends certain Medicare enrollment screening requirements for non-certified Part B suppliers, physicians, and non-physician practitioners. This includes waiver of the application fee, criminal background check, and site visits. 
  • Postpones all revalidation actions. 
  • Expedites any pending or new applications. 
  • Establishes a toll-free hotline for providers to enroll and receive temporary Medicare billing privileges. Hotlines are specific to each Medicare Administrative Contractor (MAC); click here to locate your hotline number. 
  • Allows practitioners to render telehealth services from their home without updating their Medicare enrollment information with their home address. 

Provider Location & Licensure

Allows licensed providers to render services outside their state of enrollment for purposes of billing Medicare and Medicaid if the following conditions are met: 
  1. the physician or nonphysician practitioner must be enrolled as such in the Medicare program;
  2. the physician or nonphysician practitioner must possess a valid license to practice in the state which relates to his or her Medicare enrollment;
  3. the physician or non-physician practitioner is furnishing services – whether in person or via telehealth – in a State in which the emergency is occurring in order to contribute to relief efforts in his or her professional capacity; and  
  4. the physician or non-physician practitioner is not affirmatively excluded from practice in the state or any other state that is part of the 1135 emergency area.  
This waiver does not have the effect of waiving state or local licensure requirements or any requirement specified by the state or a local government. These will continue to apply unless waived by the state. Therefore, in order for the physician or non-physician practitioner to avail him- or herself of the enrollment waiver under the conditions described above, the applicable State must also waive its licensure requirements. A physician or non-physician practitioner may seek a licensure waiver from CMS by contacting the Medicare Provider Enrollment Hotline for the MAC that services their geographic area. 

Medicare Physician Supervision Requirements

In general, during the PHE, direct supervision is defined as a virtual presence through the use of interactive telecommunications technology, for services paid under the PFS, as well as for hospital outpatient services. The revised definition of direct supervision also applies to pulmonary, cardiac, and intensive cardiac rehabilitation services during the PHE. Additionally, CMS changed the supervision requirements from direct supervision to general supervision, and to allow general supervision throughout hospital outpatient non-surgical extended duration therapeutic services. Most other therapeutic hospital outpatient services have been subject to general, rather than direct, supervision requirements since January 1, 2020. General supervision means that the procedure is furnished under the physician’s overall direction and control, but that the physician’s presence is not required during the performance of the procedure. General supervision may also include a virtual presence through the use of telecommunications technology but we would note that even in the absence of the PHE general supervision could be conducted virtually, such as by audio-only telephone or text messaging. 

Modification of 60-day Limit for Locums Tenens

CMS is modifying the 60-day limit in locum tenens regulations to allow a physician or physical therapist to use the same substitute for the entire time he or she is unavailable to provide services during the COVID-19 emergency, plus an additional period of no more than 60 continuous days after the public health emergency expires. Without this flexibility, the regular physician or physical therapist generally could not use a single substitute for a continuous period of longer than 60 days and would instead be required to secure a series of substitutes to cover sequential 60-day periods.


Audits and Medical Reviews

HHS announced it is suspending most Medicare Fee-For-Service (FFS) medical reviews during the emergency period due to the COVID-19 pandemic. This includes pre-payment medical reviews conducted by MACs under the Targeted Probe and Educate (TPE) program and post-payment reviews conducted by the MACs, Supplemental Medical Review Contractors, and/or Recovery Audit Contractors (RACs). No additional documentation requests will be issued for the duration of the PHE for the COVID-19 pandemic. This suspension of medical review activities is for the duration of the public health emergency however CMS may conduct medical reviews during or after the emergency if there is an indication of potential fraud. 

Physician Self-referral "Stark" Law

CMS implemented waivers that exempt providers from sanctions for noncompliance of certain Stark Law rules, permitting certain referrals and the submission of related claims that would otherwise violate the Stark Law.

Alternative Payment Models (APMs)

CMS broadened program parameters, uncontrollable circumstances policies, and extended deadlines for three models, outlined below. CMS does not establish broad flexibilities, deadline extensions, or accommodations for APMs more generally, though it “recognizes current regulations may be insufficient and additional actions may be necessary … [and] will consider additional rulemaking to amend or suspend APM QPP policies as necessary in light of the public health emergency due to COVID-19.”

Medicare Shared Savings Program (MSSP)
  • For financial reconciliation for the 2020 performance year, CMS will reduce the amount of an ACO's shared losses by the percentage of total months of the performance year affected by an extreme and uncontrollable circumstance (January 2020 through the end of the COVID-19 public health emergency). Additionally, payment amounts for episodes of care (as identified by inpatient care for treatment of COVID-19) will be removed from MSSP performance year expenditures.
  • ACOs whose current agreement periods expire on December 31, 2020 have the option to extend their existing agreement periods by one year (ACOs extending their agreements for an additional year would remain under their existing historical benchmarks for an additional year). CMS announced that it will cancels the 2021 MSSP application cycle for new ACOs.
  • ACOs in the Basic Track’s glide path have the option to maintain their current level of participation for performance year 2021, therefore not assuming a higher level of risk.
  • Expands the definition of primary care services used in the MSSP assignment methodology to include services provided virtually, through telehealth, virtual check-ins, e-visits or telephone, effective January 1, 2020, and for any subsequent performance year that starts during the PHE.
Medicare Diabetes Prevention Program
  • CMS will permit certain beneficiaries to obtain the set of MDPP services more than once per lifetime to allow beneficiaries to remain eligible for MDPP services despite a temporary break in service, attendance, or weight loss achievement. 
  • CMS will also waive the limit to the number of virtual make-up sessions, so long as they are requested by the beneficiary and furnished consistently with CDC standards. The Agency will allow certain MDPP suppliers to deliver virtual MDPP sessions on a temporary basis or suspend in-person services and resume services at a later date, within certain parameters. Virtual make-up visits will not count toward weight loss goals, only attendance.  
Comprehensive Care for Joint Replacement (CJR) Model

CMS will extend the length of Performance Year 5 by three months such that the model will end on March 31, 2021, rather than Dec. 31, 2020. CMS also changed the extreme and uncontrollable circumstances policy to account for all participant hospitals affected by the COVID-19 pandemic. 

MGMA Advocacy and Other Resources

MGMA analysis of the COVID-19 financial impact on medical practices

MGMA analysis of the COVID-19 policies of major national health payors (updated 5/28/20)

MGMA Advocacy

  • MGMA sends letter of support for Senate version of PPP Flexibility Act
  • MGMA sends letter of support for the Paycheck Protection Program Flexibility Act (May 20)
  • MGMA comments on several provisions of the HEROES Act (May 14)
  • MGMA joins coalition asking CMS provide additional relief for ACOs (May 14)
  • MGMA urges SBA to release additional guidance on PPP loan forgiveness (May 6)
  • MGMA asks HHS for clarity on terms and conditions associated with CARES Act Provider Relief funds (April 21)
  • MGMA asks HHS/CMS to account for providers with low Medicare volumes in next round of CARES Act relief funds (April 16)
  • MGMA urges Congress to protect the financial viability of group practices (April 15)
  • MGMA survey sheds light on dire financial impact of COVID-19 on physician practices (April 14)
  • MGMA recommends improvements for Medicare's MIPS Value Pathways Program (April 10)
  • MGMA asks CMS to encourage MA and Part D plans to relax PA and step therapy requirements during COVID (April 10)
  • MGMA statement in response to HHS's initial distribution of $30 billion in grant funds for providers under the CARES Act (April 10)
  • MGMA joins coalition calling on CMS for E/M payment parity changes and additional telephone E/M guidance for MACs (April 8)
  • MGMA joins coalition requesting emergency funding for physicians from HHS (April 7)
  • MGMA urges  HHS to immediately begin financial support of medical groups (March 27)
  • MGMA urges HHS to further waive telehealth restrictions following CARES Act (March 27)
  • Statement on emergency funding for medical practices (March 27)
  • Together with a coalition of leading stakeholder groups, MGMA urges Congress to leverage health IT during COVID-19 emergency (March 23) 
  • MGMA joins a coalition to call on Congress to ensure sustainability of physician practices during COVID-19 emergency (March 20)
  • MGMA calls on Congress to suspend appropriate use criteria (AUC) program, together with industry coalition (March 20)
  • MGMA recommends Congress to provide direct financial assistance to group practices and take further action on COVID-19 (March 18)
  • MGMA joins coalition recommending the Senate, House, and Administration ensure access to Medicare value-based care during COVID-19 pandemic (March 18)
  • MGMA asks HHS to exercise telehealth waiver authority (March 11)
To read about our advocacy efforts on other issues, please visit our advocacy letter archive. To use our grassroots portal to get involved in advocacy, visit our Contact Congress portal

CMS/HHS Guidance

CDC Guidance

Other Resources


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