Frequently Asked Questions are used to provide additional information and/or statutory guidance not found in State Medicaid Director Letters, State Health Official Letters, or CMCS Informational Bulletins. The different sets of FAQs as originally released can be accessed below.
Frequently Asked Questions
For evaluating the claims history under CMS 2370-F, must we use all "billed" claims, including denied claims or claims that are subsequently voided? We would propose to use all paid claims net of voids and adjustments.
If a physician does not provide an attestation by a date established by the State, can the State apply the increased payment under CMS 2370-F prospectively only (that is, to dates of services on and after the date of attestation)? If not, are we correct that 42 CFR 447.45(d)(1) applies such that the claim for additional reimbursement is not payable if the attestation is not received within 12 months of the date of service?
States can establish reasonable timeframes regarding the submission of attestations by physicians. We are aware that many states are experiencing delays in implementing the provisions of the regulation and we have also been made aware that there is considerable confusion on the part of providers regarding enrollment. We expect that states will provide physicians with ample notice of the procedures for enrollment that physicians will be given several months to comply with the requirements. If the state sets a reasonable timeframe, such as three months, and physicians do not enroll within that time, we believe that the state could make payment prospectively from the date of the physician's application as long as this policy is made clear to providers.
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FAQ ID:93981
SHARE URLDoes a physician have to self-attest under CMS 2370-F in 2014 as well as 2013? The rule does not indicate that the physician has to self-attest a second time and we don't want to do that, but some who qualified in 2013 (based on 2012 claims history) may not qualify in 2014 (based on 2013 claims history).
You are correct that the rule does not require the physician to submit a new self-attestation in 2014 although states could impose such a requirement. States can rely on the initial self-attestation for purposes of 2014 payments since we would not expect provider practices to vary significantly from year to year.
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FAQ ID:93991
SHARE URLWhat form must a physician use to self-attest and qualify for higher payment under CMS 2370-F under this provision?
Attestation forms are developed by the State Medicaid agencies. Physicians should contact their state Medicaid agency for information on the process for becoming eligible for higher payment in their state.
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FAQ ID:93996
SHARE URLWhile sports medicine is a subspecialty of internal medicine, it is also a subspecialty of non-primary care specialties? We would only qualify a physician for the board certification for the sports medicine subspecialty under CMS 2370-F when it is a subspecialty of internal medicine. Is this correct?
With respect to self-attestation, if a provider only meets the 60 percent threshold or only meets the Board certification under CMS 2370-F, would the provider only have to attest to that one component to be eligible or is it necessary to meet both components?
Physicians must first self-attest to a primary care designation of internal medicine, family medicine or pediatrics. This attestation signifies that the physicians consider themselves to be eligible specialty practitioners. The self-attestation must then indicate whether the physicians consider themselves to be qualified because of appropriate Board certification or practice history as represented by a 60 percent claims history. Some physicians may be appropriately Board certified and have a 60 percent claims history.
There may be physicians with Board certification in a specialty not recognized for higher payment under the rule who actually practice as pediatricians, family practitioners or internists who would be eligible for higher payment. For example, an Obstetrician/Gynecologist (OB/GYN) who no longer practices in that specialty but practices as a family practitioner could appropriately self-attest to being a primary care provider. Such a provider would need to qualify based on the 60 percent threshold and not Board certification. Physicians that support their initial self-attestation with an attestation of appropriate Board certification can qualify only if they actually have the appropriate Board certification. Practice habits would not be applicable.
There may also be physicians with Board certification in one of the three eligible specialty areas who do not actually practice in those areas. They should not self-attest to being a primary care provider.
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FAQ ID:94016
SHARE URLHow should a physician who is certified in internal medicine, family practice or pediatrics by a Board other than the ABMS, the AOA or the ABPS self-attest under CMS 2370-F?
We understand that Deloitte (Center for Medicare & Medicaid Services contractor) will be calculating the average GPCI values across counties for each state to use in paying primary care providers under CMS 2370-F. When can we expect those values to be disseminated? Will the formula weight each county equally, or will some alternative weight be used based on county population or some other factor?
The Center for Medicare & Medicaid Services (CMS) disseminated the Deloitte fee for service tool to states through the CMS Regional Offices in early January. It permits states to develop rates for each code based on the decisions it makes about site of service and geographic adjustments. The formula used to develop the rate weights each county equally and does not incorporate a weighting factor for population. Using a rate weighted by population is not an option for states to use in developing their fee schedules.
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FAQ ID:94036
SHARE URLWe received the Deloitte Excel model but have been unable to open some of the files. Can you help?
CMS can produce the fee schedules for states that are unable to run the program. States should contact Christopher Thompson at Christopher.thompson@cms.hhs.gov.
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FAQ ID:94046
SHARE URLFor physicians in neighboring states, can we require them to self-attest under CMS 2370-F using our state's protocol, rather than relying on the determination made by the home state's Medicaid program?
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