less than meets the eye?

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On April 4, CMS announced the coverage of Over the Counter (OTC) COVID-19 tests by Medicare, and released a fact sheet along with guidance for providers on the coverage and billing requirements and guidance for beneficiaries on how to obtain cost-free tests. According to these documents, coverage for these tests began April 4 and will continue through the duration of the COVID-19 Public Health Emergency (PHE). The COVID-19 PHE was last renewed on January 14, which would extend the PHE through April 16, 2022. However, on January 21, 2021, Acting Secretary of HHS Norris Cochran sent a letter to State Governors indicating that:

… when a decision is made to terminate the declaration or let it expire, HHS will provide states with 60 days’ notice prior to termination.

To date (April 11, 2022), it does not appear that any notification of the termination of the PHE has been issued by the Secretary, but neither has the PHE been renewed. (UPDATE: The PHE was renewed on April 12, posted to the DHHS website on April 13. The PHE will, after this renewal, expire on July 16 unless again renewed.)

Despite all of this busyness a fair amount remains uncertain. Beneficiaries are right to be confused—as am I. Will the PHE expire on April 16? Or will the Department renew the PHE in the next 5 days? Or will it continue until such time as the Department notifies the states that it has made a decision to terminate the declaration? If so, then why has the Department renewed the PHE three times since the letter to the Governors was sent—on April 15, July 19, October 15, 2021, and again on January 14, 2022?

If the PHE does expire on April 16, 2022, then the “coverage” of COVID-19 tests is more sound than substance. So presumably a renewal of the PHE is forthcoming … but why the needless confusion?

Somewhere, if only in my mind, Max Weber is weeping.

On another note, the guidance given to providers indicates that Medicare will pay the lesser of $12 per test or the amount charged by the participating pharmacy or provider—$24 is the retail price for a package of 2 Binax tests at Walgreens.

 

federal register • 06 april 2022

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CMS has published in the federal register:

  • Proposed Rules for the Medicare Program: Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2023 and Updates to the Inpatient Rehabilitation Facility Quality Reporting Program
  • A Notice of Agency Information Collection Activities:
    1. Medicare Coverage of Items and Services in FDA Investigational Device Exemption Clinical Studies—Revision of Medicare Coverage
    2. Medicare Coverage of Items and Services in FDA Investigational Device Exemption Clinical Studies—Revision of Medicare Coverage

federal register • 04 april 2022

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CMS has published in the federal register:

  • Proposed Rules for the Medicare Program: Fiscal Year 2023 Inpatient Psychiatric Facilities Prospective Payment System—Rate Update and Quality Reporting
  • Proposed Rules for the Medicare Program: FY 2023 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements
  • A Notice of Agency Information Collection Activities:
    1. Medicare Current Beneficiary Survey (MCBS)
    2. Application and Triennial Re-application to Be a Qualified Entity to Receive Medicare Data for Performance Measurement

federal register • 29 march 2022

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CMS has published in the federal register:

  • A Notice of Agency Information Collection Activities:
    1. Continuation of Data Collection to Support QHP Certification and other Financial Management and Exchange Operations
    2. Prepaid Health Plan Cost Report
  • A Notice of Agency Information Collection Activities for Medicaid and the Children’s Health Insurance Program:
    1. Coverage of Routine Patient Cost for Items & Services in Qualifying Clinical Trials
    2. Expressions of interest in the Improving Maternal Health by Reducing Low-Risk Cesarean Delivery Affinity Group

and what to make of this?

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Man that is born of a woman hath but a short time to live, and is full of misery. He cometh up, and is cut down like a flower; he fleeth as it were a shadow, and ne’er continueth in one stay
—The Book of Common Prayer (1662)

Diuturnity is a dream and folly of expectation.
—Sir Thomas Browne, Urne Buriall

While of death, there is little to be said that is truly to the point, of dying there is too much.
—Raymond Tallis, The Black Mirror

This morning on NPR’s Saturday Edition Scott Simon announced—portentously, as he so often does—that: “Senior citizens, people over 65, account for 16% of the U.S. population but 75% of deaths from COVID-19, according to the CDC.”

It’s not clear what to make of this factoid. In 2019, according to the CDC, before anyone had heard of COVID, people 65 years of age or older were 16% of the U.S. population and 74% of deaths. And in 2010, old people (among whom I number myself) were 13% of the U.S. population and 73% of deaths.

But, as Scott might say, mercy! it’s even worse than this. In 2020, people 75 years of age or older were just 7% of the population but 54% of deaths. And—oh lordy—people 85 years of age or older were 2% of the population but 30% of deaths!!

This may mean that there is an epidemic of death among the elderly. Or that a leading cause of death is old age. Or that death follows, inevitably, from being born.

For a sobering comparison, compare the statistics for the Republic of South Africa, where people aged 65 or older, in 2017, were 5% of the population but 36% of deaths. People between the ages of 35 and 44 comprised 13% and 14% of the population in the U.S. and the R.S.A., respectively, but accounted for less than 3% of deaths in the U.S. and more than 12% of deaths in the R.S.A.

So perhaps the statistics which seemed to give Scott the vapors mean simply that, in the United States, “senior citizens”—however old they may be—are lucky to be not dead yet.

federal register • 11 february 2022

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CMS has published in the federal register:

  • A Notice of Agency Information Collection Activities:
    1. Affordable Care Act Internal Claims and Appeals and External Review Procedures for Non-grandfathered Group Health Plans and Issuers and Individual Market Issuers
    2. LTCH CARE Data Set for the Collection of Data Pertaining to the Long-Term Care Hospital Quality Reporting Program

federal register • 10 february 2022

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CMS has published in the federal register:

  • A Correction to Final Rules for the Medicare Program:
    1. CY 2022 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements;
    2. Provider Enrollment Regulation Updates;
    3. Provider and Supplier Prepayment and Post-Payment Medical Review Requirements

federal register • 09 february 2022

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CMS has published in the federal register:

  • A Notice of Agency Information Collection Activities: 
  • A Notice for the Medicare and Medicaid Programs: Quarterly Listing of Program Issuances, October through December 2021
  • A Notice for the Medicare Program: Request for an Exception to the Prohibition on Expansion of Facility Capacity under the Hospital Ownership and Rural Provider Exceptions to the Physician Self-Referral Prohibition