It’s time to make sure you’ve decided how to best take advantage of this one last six-month deadline extension.
The Department of Health & Human Services issued a memo May 18, 2022, for the Centers for Medicare & Medicaid Services (CMS), explaining that it will be “conducting an Interim Final Run with data submitted as of the usual final risk adjustment data submission deadline for Payment Year (PY) 2022.” The Interim Final Run risk scores will be used in a reconciliation payment run on the same schedule as that typically used for the final reconciliation payments for a year. The deadline for submission of risk adjustment data for this Interim Final Run for PY2022 was January 31, 2023.
There will also be a Final Run for PY2022. The deadline for submission of risk adjustment data for the PY2022 Final Run is July 31, 2023. This provides a six-month deadline extension for data submissions, which will be used to conduct a final payment reconciliation.
With the January 31 deadline for the PY2022 Interim Final Run now behind us, it’s time to make sure you’ve decided how to best take advantage of this one last six-month deadline extension (due to COVID-19). One option that organizations may have opted for was to stick with the original January 31 deadline for submission of their risk adjustment data. While this has the probable advantage of more rapid payment from CMS, since there is a six-month delay, this may also delay the final reconciliation payment to a date that is still to be determined.
However, using the submission deadline extension offers advantages as well—advantages beyond providing you with some extra time to catch your breath and get your data together. This extension could help you create a cleaner, more accurate, more complete risk adjustment data submission for that July 31 PY2022 Final Run deadline. You will want to seriously consider your options before deciding which deadline to use.
Ways to make the most of this opportunity
Improve diagnostic coding accuracy: An extra six months before the PY2022 Final Run submission deadline gives you an opportunity to improve the accuracy and completeness of your coding.
Accurate diagnostic coding is critical for both health plans and patients. For patients, accurate diagnostic coding is essential for them to receive the care required for their condition. For health plans, missing or late diagnoses can prevent you from obtaining the appropriate funding for patients’ required care.
Despite their importance, though, diagnostic coding errors are common. Consider:
- ICD-10 coding in patients’ medical records can have error rates ranging from about 20 percent to 50 percent
- More than 40 percent of patients’ chronic conditions are never reported by their providers
- Even among claims that display accurate, specific patient diagnoses, about 30 percent fail to pass the CMS validation process due to a lack of supporting documentation
This is why an opportunity to conduct secondary reviews of coded charts for the 2021 dates of service is invaluable.
An extra six months also provides you with time to retrieve any charts that might be missing, using low-friction retrieval methods. For instance, electronic clinical data exchange solutions exists which can automate the exchange of patient information between payers and providers, making data exchange faster and more efficient. Where standard chart retrieval processes might take months, this technology can integrate with multiple types of electronic health records (EHRs) and perform these data transfers in minutes.
The best fit for your coding needs: It will also be important to consider which would best fit your chart coding needs:
- An automated coding software system
- An external consulting solution, bringing in an external team of experts to provide coding assistance
Assuming you don’t have the knowledge or staff availability in-house, as many organizations do not, seeking expert help from third-party consultants can be an effective solution in some cases. Alternately, automated solutions are increasingly popular, and leverage advanced technologies to enable health plans to identify, document, and validate more efficiently and accurately those conditions for which your members were treated. For some solutions, coding performance can be optimized using computer-aided coding technologies, such as Natural Language Processing, Machine Learning, and Optical Character Recognition to optimize coding performance.
What’s your plan?
The January 31, 2023 deadline for submission of risk adjustment data for the PY2022 Interim Final Run is now behind us—but even though that was originally the deadline for data submissions for the PY2022 Final Run, you have an additional six months before that final deadline, should you choose to use it. If you do delay your risk adjustment data submission until the PY2022 Final Run deadline, you will have until July 31, 2023 to improve your coding accuracy, identify and address gap closure opportunities, and review your data to ensure everything is in order.
Should you choose to use that delay, be sure to make the most of this unique opportunity by finding the best solution to fit your risk adjustment and quality needs. Seek out the input of knowledgeable peers, third-party consultants, or health care technology vendors to help get all you can from these six months.
About the author
Lesley Weir, senior director of customer and product success at Veradigm, has over 30 years’ experience in the Medicare Managed Care industry, with specific expertise in operations, risk adjustment, and quality improvement. She has a demonstrated track record of assisting health plans in meeting operational and revenue goals, as well as developing innovative strategies to improve member’s health and experience. Prior to her role at Veradigm, she held various leadership positions at multiple provider-owned Medicare Managed Care Health Plans and a large national plan. She also spent six years working in the vendor space supporting Medicare Advantage plans across the country with their risk adjustment and quality programs.