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September 24, 2020
Celebrating 228 Years
1792 - 2020
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HCMA Fighting for Medical Advocacy
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Recognition of All the Hard Working Women in Medicine
As the month of September comes to a close, we pay tribute to the commitment and dedication of all the hard working women in medicine in Connecticut and throughout the nation. September is designated as Women in Medicine Month by the American Medical Association. Women have a special place in the field of medicine and we are grateful for the critical contributions they make each and every day.
According to the Association of American Medical Colleges (AAMC), only one in 10 medical students in the United States was a woman in 1965. For the first time ever in 2017, more women were enrolled in U.S. medical schools than men, and that positive trend continues today. While the journey to ensure gender equality in our field is far from complete, great progress has been made since Elizabeth Blackwell became the first female doctor in 1849—a tribute to all of the great female providers who have followed this trailblazer.
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The 14 Day COVID-19 Quarantine is no longer required in all cases
Connecticut’s Governor Ned Lamont issued Executive Order 9B , which calls for a welcome COVID-19 testing alternative to mandatory self-quarantine for those individuals coming into Connecticut from states and US territories on Connecticut’s Travel Advisory list . As we wrote previously (click here to read article), prior to Executive Order 9B, almost all individuals coming into Connecticut from a state or US territory on the Travel Advisory list had to self-quarantine for 14 days. There were only narrow exceptions to self-quarantine, including individuals traveling due to an emergency and individuals not staying in the foreign state for more than 24 hours.
Now everyone can test out of Connecticut’s mandatory 14 day self-quarantine requirements through two options. First, get tested within 72 hours before entering the state and receive a negative test result (until you get the results you must remain quarantined). Alternatively, be tested in Connecticut after entering the state and receive negative results. Again, you must remain quarantined until you get the results. Employees and employers should be aware the state is currently only accepting results for nucleic acid COVID-19 tests, such as reverse transcriptase polymerase chain reaction (RT-PCR) tests.
Executive Order 9B provides a carve out for “Essential Workers” traveling to, or returning to Connecticut from states on Connecticut’s Travel Advisory list when such travel is related to their work. However, if such travel was non-work related (e.g., vacation), such workers shall be required to follow the self-quarantine/testing procedures detailed above.
Executive Order 9B also covers individuals coming into Connecticut from countries on the CDC’s Level 3 Travel Health Notice. Connecticut employers are encouraged to review Executive Order 9B for specific testing and reporting requirements.
(Brody and Associates)
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Sexual Harassment Prevention Training Deadline Extended
Good news for Connecticut medical practices and other employers: the Commission on Human Rights and Opportunities updated its deadline for employers to complete sexual harassment prevention training by giving a blanket 90-day extension of time for all employers. Previously, that deadline was set for October 1, 2020 and extensions were only granted upon request.
Now, with the Connecticut Governor extending the state of emergency through February 2021, the deadline for training has been extended to January 1, 2021 for all employers without the need to seek an extension.
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The Hartford County Medical Association
invites you to its first virtual annual meeting
that will be hosted online using ZOOM
228th Annual Meeting and Physician Award Ceremony
Thursday, October 22, 2020 at 6:00 PM
Save the date!
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Additional information will be forthcoming
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Governor Ned Lamont announced that as companies continue navigating the impact of the ongoing, global COVID-19 pandemic, the State of Connecticut will be expanding its Shared Work program, which helps businesses in the state prevent layoffs by allowing them to temporarily reduce employee hours and use partial unemployment benefits to supplement lost wages. The program will be expanded beginning the week of October 5, 2020.
The Shared Work program helps employers retain a talented workforce during economic downturns. Rather than laying off the workforce – and having to recruit, hire, and train new labor when the economy recovers – Shared Work employers are able to reduce overhead by temporarily cutting hours. Their employees keep their jobs at a reduced schedule, keep their benefits, and are able to file for partial unemployment benefits for the lost wages. Employer eligibility includes companies with two or more workers that have hourly reductions within 10 to 60 percent of normal hours, provided that the lost hours are not related to seasonal separations. Shared Work runs for a maximum of six months for each employee.
Medical practices interested in participating in Shared Work can apply with the Connecticut Department of Labor. For more information on the program and the application process, click here.
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The Connecticut Department of Revenue Services (DRS) launched a new, online tax filing and payment portal called DRS myconneCT. Certain taxes filed by businesses are included in the initial phase, and the program will eventually include all state tax filings made with DRS.
The new portal is the second development from DRS this year. In July, the website business.ct.gov was launched to serve as a one-stop-shop for businesses in an effort to streamline and modernize government services.
Taxpayers can now create a myconneCT username and use the system to file state returns, make payments, and view their filing histories, among other self-service options, for the following business state tax types administered by DRS:
- Sales and Use/Business Use
- Withholding
- Room Occupancy (B&B Occupancy)
- Prepaid Wireless E 9-1-1 Fee
- Admissions and Dues
- Tourism Surcharge
- Rental Surcharge
- Dry Cleaning Surcharge
In the future, DRS will add additional types of state tax that can be filed with myconneCT. For more information about myconneCT check out the DRS website.
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Governor Lamont signs 70th executive order to mitigate the spread of COVID-19
Governor Lamont signed another executive order – the 70th since he enacted the emergency declarations – that builds upon his efforts to encourage mitigation strategies that slow down transmission of the virus.
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Amendments to mandatory self-quarantine for travelers from states with high COVID-19 levels: Modifies the state’s previously issued self-quarantine and travel advisory order for people arriving to Connecticut from impacted states, expanding the testing exemption to all travelers who test negative for COVID-19 in the 72 hours prior to arrival. This takes effect at 12:01 a.m. on Friday, September 18, 2020.
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Authorization for the issuance of fines: Authorizes the commissioner of Public Health, local health departments, municipal chief elected officers, and state and local police to issue fines for violations of certain COVID-19 protective measures. These include:
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A fine of $100 for an person who fails to wear a mask or cloth face covering as required under Executive Order No. 7NNN;
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A fine of $500 for any person or business entity who organizes, hosts, or sponsors a gathering that violates the gathering size restrictions set forth in the DECD Rules for Gatherings and Venues and Sector Rules for Outdoor Events; and
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A fine of $250 for any person who attends a gathering that violates the gathering size restrictions set forth in the DECD Rules for Gatherings and Venues and Sector Rules for Outdoor Events.
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UNITED STATES DEPARTMENT OF LABOR NARROWS FAMILIES FIRST CORONAVIRUS RESPONSE ACT’S DEFINITION OF “HEALTH CARE PROVIDER”
On September 11, 2020, the United States Department of Labor (“DOL”) revised a definition of who is a “health care provider” for purposes of excluding those employees, i.e., not providing federal paid sick leave, from the Families First Coronavirus Response Act (“FFCRA”). The Revised Final Rule significantly narrows the prior definition, and employers in the health care industry should review and revisit their policies regarding eligible coverage (or exemption) under the FFCRA. That revised Rule took effect on September 16, 2020. Click here to read more.
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Quality Payment Program
MIPS Extreme and Uncontrollable Circumstances Exception due to COVID-19
The COVID-19 pandemic has impacted all clinicians across the United States and territories. However, we recognize that not all practices have been impacted by COVID-19 to the same extent. For the 2020 performance year, we will be using our Extreme and Uncontrollable Circumstances policy to allow clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more Merit-based Incentive Payment System (MIPS) performance categories due to the current COVID-19 public health emergency.
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Two Weeks Remaining to Submit MIPS Targeted Review Requests
If you participated in the Merit-based Incentive Payment System (MIPS) in 2019, your performance feedback, including your MIPS final score and payment adjustment factor(s), is now available for review on the Quality Payment Program website.
This final score determines the payment adjustment you will receive in 2021, with a positive, negative, or neutral payment adjustment being applied to the Medicare paid amount for covered professional services furnished by a MIPS eligible clinician in 2021.
MIPS eligible clinicians, groups, and virtual groups (along with their designated support staff or authorized third-party intermediary), including APM participants, may request the Centers for Medicare & Medicaid Services (CMS) to review the calculation of their 2020 MIPS payment adjustment factor(s) through a process called targeted review. The deadline to submit your request is October 5, 2020 at 8:00 p.m. (EDT) – which is only 2 weeks away.
When to Request a Targeted Review
If you believe an error has been made in your MIPS payment adjustment factor(s) calculation, you can request a targeted review until October 5, 2020 at 8:00 p.m. (EDT). Some examples of previous targeted review circumstances include the following:
- Errors or data quality issues for the measures and activities you submitted
- Eligibility and special status issues (e.g., you fall below the low-volume threshold and should not have received a payment adjustment)
- Being erroneously excluded from the APM participation list and not being scored under the APM Scoring Standard
- Performance categories were not automatically reweighted even though you qualify for automatic reweighting due to extreme and uncontrollable circumstances
Note: This is not a comprehensive list of circumstances. CMS encourages you to submit a request form if you believe a targeted review of your MIPS payment adjustment factor (or additional MIPS payment adjustment factor, if applicable) is warranted.
How to Request a Targeted Review
You can access your MIPS final score and performance feedback and request a targeted review by:
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Going to the Quality Payment Program website
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Logging in using your HCQIS Access Roles and Profile System (HARP) credentials; these are the same credentials that allowed you to submit your MIPS data. Please refer to the QPP Access Guide for additional details.
CMS may require documentation to support a targeted review request that is under our evaluation. If the targeted review request is approved, we may update your final score and/or associated payment adjustment (if applicable), as soon as technically feasible. Please note that targeted review decisions are final and not eligible for further review.
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There is significant evidence that increasing consolidation of provider organizations has been associated with higher prices, but it’s been argued that the quality of care is also improved. This study found “Greater financial integration was generally not associated with better quality.”
(Health Affairs)
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Congress Urged to Waive “Budget Neutrality” to Prevent Steep 2021 Medicare Cuts
The 2021 Medicare Physician payment rule advanced by CMS contains a number of important changes, including reduced documentation for E&M codes and long overdue increases for office visits. However, of great concern it also sets forth an 11% cut to the Medicare conversion factor, greatly limiting the benefit of these other increases and potentially causing great harm to many practices.
The conversion factor cut is required due to statutory “budget neutrality” requirements that prohibit increases without corresponding decreases. MSSNY and many other groups are urging Congress to pass legislation to waive these “budget neutrality” requirements to prevent devastating cuts and permit needed changes to go forward. You can send a letter to supplement these efforts here:
- Of significant concern, the proposed CY 2021 Medicare Physician Fee Schedule (PFS) conversion factor is $32.26, which represents an almost 11% reduction from the CY 2020 conversion factor of $36.09. This is the result of positive adjustments in other parts of the rule. As a result, the AMA and many other societies are pushing for Congress to waive these problematic budget neutrality requirements.
- Similarly, the proposed CY 2021 anesthesia conversion factor is $19.96, down 10% from the CY 2020 anesthesia conversion factor of $22.20.
- The AMA/Specialty Society RVS Update Committee (RUC)’s recommendations account for only half of the reduction. The remaining spending increases and resulting conversion factor reduction is attributed to various CMS proposals to increase valuation for specific services.
- CMS proposed to accept approximately 75% of the RUC recommendations for Physician Work RVU Updates. Updates to the direct practice expense inputs are proposed for individual codes based on RUC recommendations. The proposed rule does not include the 1.0 work geographic practice cost index (GPCI) floor.
- CMS proposes to implement finalized CPT descriptors, guidelines and payment rates effective on January 1, 2021, which will be a significant modification to the coding, documentation, and payment of evaluation and management (E/M) services for office and outpatient visits: retain 5 levels of coding for established patients, reduce to 4 levels for new patients, and revise code definitions. CMS revalues services analogous to office outpatient E/M visits.
- CMS proposes to allow the three G-codes used to report opioid use disorder (OUD) to also be used for monthly treatment reporting for patients with substance use disorder (SUD) as well. So that they could be used to report monthly treatment of patients with any SUD, not just OUD.
- CMS has proposed to permanently keep several codes that were temporarily added to the Medicare telehealth list, including the prolonged office or outpatient E/M visit code and certain home visit services. CMS also proposes to keep additional services, including certain emergency department visits, on the Medicare telehealth list until the end of the calendar year in which the PHE ends to allow more time to study the benefit of providing these services using telecommunications technology outside the context of a pandemic.
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The shortage is a dangerous failure for hundreds of thousands of nurses re-wearing disposable respirator masks.
(Washington Post)
Note: The Association headquarters still has a supply of KN-95 masks if you are in need.
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NEJM Publishes Free Articles for Physicians on COVID-19
NEJM published a collection of articles and other resources on the Coronavirus (Covid-19) outbreak, including clinical reports, management guidelines, and commentary. All NEJM content related to the Covid-19 pandemic is freely available. NEJM COVID-19 page
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