CMS Submission Deadline Extension Clarification

Health Fidelity Chris GluhakOn 9/18/20, CMS announced a submission deadline extension option for 2019 dates of service (DoS) for Medicare Advantage organizations, PACE organizations, Medicare-Medicaid plans, and other cost contractors from 2/1/21 to 8/2/21.

The announcement created some confusion, namely that the 2/1/21 deadline still existed alongside the 8/2/21 final deadline. There wasn’t clear direction on why nor what it entailed for the 2020 payment year.

As a result of this unorthodox approach with two apparent deadlines, MAOs have responded in different ways, some still targeting the original February submission, others focusing on the August extension. In light of our relationship with parties at health plans, provider organizations, and other technology partners within the healthcare industry, we reached out directly to CMS for clarification on the financial consequences of an MAO choosing to depart from the 2/1/21 date, and whether CMS may have had any other motivation beside the COVID-19 related delays in introducing the second deadline.

Their response confirmed that the extension is exclusively the result of the economic and operational impact on MAOs due to COVID-19. In their own words, CMS wanted to strike a balance between ensuring high quality beneficiary care and completing timely risk adjustment data submissions. In doing so, they hoped to find the middle ground between seeking the standard, timely reimbursement payments while also offering some breathing room in light of COVID-19. By keeping both dates in play, organizations able (or trying to) to stay the course operationally would experience no delay in reimbursement when choosing to complete submissions by the 2/1/21 date. For any others, the extension provides additional time to accurately and compliantly capture their assumed risk for PY2020, albeit at the cost of delaying the final reconciliation payment by a currently unknown period of time.

To summarize: risk scores and risk adjusted payment for both the interim final and final reconciliation will reflect diagnoses submitted through the applicable deadlines. This allows for those final reconciliation payments to still be sent mid-2021, based on the available risk data at 2/1/21. However, CMS will take another, final snapshot of risk on 8/2/21. The change to the risk score (higher, lower, or flat) will determine the next action, issuing an adjustment on that 2/1/21 affiliated payment at a yet unscheduled time (likely in late 2021-early 2022). We ultimately do still encourage organizations to work towards their standard 2/1/21 deadline, because the extension could come with a cost. The still unscheduled reconciliation from the 8/2/21 deadline inserts a significant variable into a risk bearing entity’s financial cycle, representing another operational disruption in its own right.

The Health Fidelity Perspective: For organizations needing to use the submission deadline extension to catch their breath, our teams are well aware of the situation and ready to support you for both dates. The same goes for organizations pushing hard to meet the original February deadline. Finally, for anyone looking to use the extra six months to drill down even further than normal, we are also fully available to provide an additional pass via Lumanent Retrospective Review.

In short, whether you take one of the three paths we’ve outlined or a different approach of your own design, we are prepared to make it as smooth and successful as possible.