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
What 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:94136
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:94146
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?
Such a physician would self-attest to a primary specialty designation of family medicine, pediatric medicine or internal medicine and would then attest to, and qualify based on, a 60 percent claims history.
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FAQ ID:94151
SHARE URLWe 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:94156
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:94161
SHARE URLCommunity clinics in my state (clinics other than Federally Qualified Health Center and Rural Health Clinic are reimbursed at the same rate as a physician. They do not receive a bundled or encounter rate. Are they eligible for the higher payment under CMS 2370-F? Would they have to attest that 60 percent of the services provided in the clinic are within the qualifying Evaluation & Management (E&M) codes? Are they required to pass through any increased payments in the form of higher wages for the health care professionals they employ?
Higher payment made under the requirements of the regulation is for physicians reimbursed pursuant to a physician fee schedule. Physicians working in a clinic and reimbursed through a physician fee schedule could qualify for higher payments if they are appropriately Board certified or if 60 percent of the services that he or she provides is for the specified primary care services. Since the clinic itself is not eligible, this percentage of services threshold cannot be based on the aggregate of all services provided by all practitioners within the facility, only on services the individual physicians.
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FAQ ID:94171
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?
What federal match rate is available to the states for administrative costs incurred from implementation of the CMS 2370-F rule?
The regular administrative federal match rate is applicable to administrative costs associated with implementation of this rule. Section 1905(dd) of the Social Security Act (the Act) authorizes increased Federal Medical Assistance Percentage (FMAP) only for eligible services provided by eligible providers pursuant to section 1902(a)(13)(C) of the Act
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FAQ ID:94226
SHARE URLAre bonus payments and other incentive arrangements for health plans included in the CMS 2370-F methodology for determining the rate differential that is eligible for 100 percent (Federal Financial Plan) FFP?
We addressed the treatment of bonus payments and other incentive arrangements in terms of identifying the 2009 base rate in the final rule and take this opportunity to clarify that such arrangements are similarly excluded from the methodology for determining the rate differential.
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FAQ ID:94236
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