MA Deadline Extensions for 21-22: CMS Policy Update and Strategy Guidance

Medicare Advantage (MA) deadline extensions for 2021-2022Earlier this year, we discussed the final call letter from CMS detailing the Medicare Advantage (MA) deadline extensions for PY 2020 (i.e. 2019 dates of service) to account for COVID-19 related disruptions. We suspected, but had no confirmation at the time, that this would continue going forward.

While CMS hasn’t made any public announcements, we have confirmed that CMS has directly communicated to Medicare Advantage Organizations that this same MA deadline extension will apply for payment years 2021 and 2022 (2020 and 2021 DOS, respectively). This is no doubt because of the long-tail impact 2020 will have on RAF capture as patient volumes and member populations stabilize over time.

Beyond that, there are additional submission dates for payment years 2022 and 2023, meaning 2023 is a return to the “normal” deadline of January with no optional extension through the third quarter.

The question then remains: What can the MA deadline extensions mean for your long-term risk adjustment strategy?

As a first step, we recently hosted a webinar that addressed how COVID-19 impacted risk adjustment operations, and what strategic approaches support both recovery and long-term success.

In the recording, you’ll see that we almost always recommend a thorough retrospective review as a starting point. How rigorously and or broadly you apply the retrospective review depends on the current date in relation to the reimbursement cycle, but the deadline extension by CMS expands the applicability of this approach by allowing for a second, or even third pass of the available data. By ensuring all possible HCCs are captured for submission, and any non-clinically valid codes are redacted to avoid audit risk, a complete and accurate picture of both population risk and revenue are essential for additional optimization.

Prospective review is another tool risk bearing entities can utilize to better identify, capture, document, and manage RAF. For example, the addition of a pre-submission coding review within the provider workflow can allow for a review of codes for ACA and Medicaid populations, the latter of which may be excluded from retrospective review in certain states. Launching a prospective program built on NLP-derived clinical suspects can also be an excellent way to ensure the full disease burden of patients are understood during the encounter. In the United States, vaccination efforts and the rebound of patient volumes as people “catch up” on condition management make it an ideal time to add prospective risk adjustment to supplement retrospective activity and further drive a complete, accurate RAF. For example, Lumanent Pre-Encounter Prep means every patient appointment will also have a list of suspected conditions that leverage the full clinical record, a step beyond the traditional claims-only programs built into many EHR platforms.

Whatever pandemic challenges your organization is looking to overcome, or what long-term goals around risk adjustment you may have, Health Fidelity is ready to support you with a full suite of NLP solutions. If you’re not even sure where to begin, we even offer a full Risk Adjustment Value Assessment to help you understand what you have to gain with more robust risk adjustment. Contact us today.