Now that 2021 has arrived, a national election recently completed, and significant changes to the health care landscape in America continuing to unfold amidst a pandemic, the time for health data preparation is here.
A recent extension of CMS deadlines has loosened time restrictions for plans to submit. In September, the Department of Health & Human Services Centers for Medicare & Medicaid Services issued the following memo on the subject of an additional PY 2020 Reconciliation Run:
“This memo is to notify Medicare Advantage Organizations, PACE Organizations, Medicare-Medicaid Plans, Section 1833 Cost Contractors and Section 1876 Cost Contractors, and Demonstrations of upcoming deadlines to submit risk adjustment data for use in calculating risk scores for Payment Years (PY) 2020, 2021, and 2022. CMS will be adding an additional reconciliation run for PY2020. All risk adjustment data (Risk Adjustment Processing System (RAPS) Data and Encounter Data System (EDS) Data) that will be included in the listed risk score runs need to be submitted by 8pm ET of the “Deadline for Submission.”
The memo effectively bought extra time for critical planning periods over the next 12-18 months. While the 2020 Interim Final Run deadline was February 1, 2021, the memo sets 2020 Final Run deadlines to August 2, 2021. The date change allows Medicare Advantage Organizations six additional months to ensure data submissions are complete and accurate.
It’s not the first time this has ever happened; final run deadlines were extended in 2017 in the wake of Hurricane Harvey, for example. But the level of advance notice and the time duration with which to refocus are unprecedented. Importantly, they create a unique opportunity for plans to complete secondary reviews of previously coded charts from 2019, to run additional analytics, identify unclosed HCC gaps, and launch supplemental chart chases wherever retrieval is low friction.
So, with all that, what will change in 2021? In short, hopefully very little.
Most plans allowed 2020 to run out with little disruption, focusing on current goals and business as usual. For all the change in the world, one of the main goals in health care and for health plans, as the pandemic continues to reduce the number of patient visits nationwide, has been continuity and consistency.
With extra time afforded by the CMS extension, plans can also focus on forward-facing goals like risk mitigation programs and audits to ensure the year is bulletproof. Plans are deeply invested in the validation work on 2019 services while ensuring that this work doesn’t impact 2020 or 2021. Full health profiles are being built for members. Second-level and targeted reviews are underway.
Notably, most plans are working as if the deadline extension didn’t exist, submitting on time and turning the focus of any gained time to the strategic work that strengthens positions.
Delivering on time in spite of the extension solves a few things. From an accrual perspective, most organizations don’t want to keep an accrual open longer than they have to in closing the books. If there’s any pickup for the plans to do, then plans are freed to get it done.
The extended window from CMS will allow plans to maximize returns, and most are working on just that. But it’s also notably not enough time to launch any major projects.
Instead, it’s a time of clerical focus. Of emphasis during the extended window are new-to-plan members who joined in 2020. Little may be known about them, and the extension is a great time to learn more about these members, their backgrounds and the locations of their services. The extra time becomes a chance to turn over every stone and rock.
One prospective timeline for optimizing the additional PY2020 Reconciliation Run, with 2019 dates of service could look as follows:
- February 2021 through July 2021: Passive chart intake.
- Through July 2021: Leverage the additional time before the Final Run submission to improve coding accuracy and completeness through second-level chart reviews.
- February 2021 through April 2021: Initiate supplemental chart chase where low abrasion retrieval methods are available (think automated EMR extraction, contracted copy services, credentialed EMR remote access)
- April 2021 through August 2021: Execute chart retrieval and review operations for 2020 dates of service.
- August 2, 2021: Final Submission deadline for PY2020.
Many providers are taking low abrasion projects with the extra run. With commercial risk adjustment happening and HEDIS starting in early 2021, providers are not only looking for more information on new members, but they are also standing up programs like Digital Direct EMR connections or validating hard to process records.
In short, there is extra time on the clock this year. For plans, this means a small window of opportunity. While most are staying conservative and trying not to overreach against the upcoming needs for 2021, HEDIS and commercial risk adjustment, they are indeed using the time to submit early, ensuring details are managed effectively and detailing member profiles with as much completion and accuracy as possible. The extra run grants the time plans need to take on second-level review. It’s how to firm up future submissions for encounters, take a second run at charts, and dot every I and cross each T.