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MGMA COVID-19 Federal Assistance and Advocacy Center

Federal Policy Resource - April 13, 2021

Disaster Planning

Policies & Procedures

Medicare Payment Policies

As the country works to combat the spread of COVID-19, MGMA is keeping medical group practices apprised of the latest regulatory and legislative developments that could affect patient care and practice operations. MGMA’s COVID-19 Federal Asistance and Advocacy 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

Click here for a matrix of federal COVID-19 financial assitance programs availalbe to medical practices.

Paycheck Protection Program (PPP)

Click here for a comprehensive analysis from MGMA on the PPP.

Click here for the Small Business Administration PPP FAQs.


HHS AND CMS Programs 

Click here for a comprehensive analysis from MGMA on the HHS Provider Relief Fund (PRF).

Click here for an MGMA resource on the CMS Accelerated and Advance Payment (AAP) Program. 


Employment Provisions

Click here for a comprehensive analysis from MGMA.


Telehealth, Telemedicine, and Other Regulatory Waivers


Click here for a comprehensive analysis from MGMA.

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)

Visit the MGMA APM webpage for more information and the latest news on APMs during COVID-19.

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 6/23/20)

MGMA resource on federal emergency powers

MGMA Advocacy

A January 2021 MGMA survey found that medical practices across the country are being left out of COVID-19 rollout efforts. The survey revealed a staggering 85 percent of independent practices and 45 percent of hospital or health system-owned practices actively seeking the COVID-19 vaccine for their patients report having obtained none to date. The majority of practices that have obtained the vaccine report only receiving enough to vaccinate 1 percent or less of their patients.
  • MGMA joins coalition to support the Protecting Access to Post-COVID-19 Telehealth Act of 2020 (August 3)
  • MGMA urges Senate to include additional assistance for medical groups in next COVID-19 legislation (July 22)
  • MGMA urges Congress to clarify that PRF payments are nontaxable (July 13)
  • MGMA joins coalition urging Congress to support the Resident Physician Shortage Reduction Act (July 9)
  • MGMA joins coalition urging HHS to implement office visit increases and waive budget neutrality (July 1)
  • MGMA urges HHS to extend public health emergency declaration (June 30)
  • MGMA joins 340 organizations to ask Congress to extend telehealth flexibilities (June 29)
  • MGMA joins coalition to ask HHS to continue telehealth waivers (June 23)
  • MGMA joins coalition urging Congress to extend PPP eligibility to nonprofit organizations in final version of next COVID-19 aid package (June 17)
  • MGMA joins coalition calling on Congress to include liability protections for physicians in the next COVID-19 relief package (June 9)
  • MGMA urges HHS to expeditiously disburse unallocated stimulus relief funds to group practices fighting the COVID-19 pandemic (June 2)
  • MGMA sends letter of support for Senate version of PPP Flexibility Act (May 22)
  • 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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