On the evening of December 1, 2020, the Centers for Medicare and Medicaid Services (CMS) released the final Physician Fee Schedule (PFS) for calendar year (CY) 2021. The rule includes finalized policies related to telehealth, the Quality Payment Program (QPP), care management and others. Provisions of this final rule become effective on January 1, 2021.

Impact of E/M changes Felt Across Physician Fee Schedule

Physicians and other health professionals are paid under Medicare Part B for services that include office visits, surgical procedures, and other diagnostic and therapeutic efforts. For payment, Medicare uses a physician fee schedule based on the relative resources typically used to furnish the service. These relative value units (RVUs) are determined for each service in the areas of physician work, practice expense, and malpractice. To calculate the Medicare fee schedule rates (i.e., amount before any modifiers, bonuses, penalties, or provider-type consideration), the RVUs are adjusted to reflect the price of local inputs and then summed and multiplied by a conversion factor.

Payment = [(RVU work x GPCI work) + (RVU PE x GPCI PE) + (RVU MP x GPCI MP)] x CF

Ten Percent Decrease in Conversion Factor Finalized for CY 2021

For CY 2021, CMS finalizes a conversion factor of $32.41 ($32.26 in proposed rue), which is an 10.2% decrease from the CY 2020 PFS conversion factor of $36.09. This decrease is due to a budget neutrality adjustment that accounts for increases finalized in the CY 2020 PFS rule for Evaluation and Management (E/M) services and expected utilization.

CMS Continues Phase-In of Changes to PE Calculation

Practice expense (PE) reflects to costs of furnishing a service that reflects general and administrative items such as office rent and personnel wages. In the final rule, CMS finalizes technical changes to the calculation of PE, including:

• Implementation of the third year of the market-based supply and equipment pricing update and
• Standard rate-setting refinements to update premium data involving malpractice expense and geographic practice cost indices (GPCIs).

E/M Alignment with AMA CPT Editorial Panel Begins

Office visits for physicians and other health professionals are paid using E/M codes that are based on complexity, site of service, and whether the patient is new or established. In total, E/M visits billed using these CPT codes make up about 40 percent of allowed charges for PFS services. As finalized in the CY 2020 PFS final rule, CMS is aligning E/M coding with changes adopted by the American Medical Association (AMA) Current Procedural Terminology (CPT) Editorial Panel, which will increase payment for E/M services in CY 2021. These changes include:

• Retain five levels of coding for established patients, reduces the number of levels to four for office/outpatient E/M visits for new patients, and revises the code definitions;
• Revise the times and medical decision-making process for all of the codes, and requires performance of history and exam only as medically appropriate; and
• Allow clinicians to choose the E/M visit level based on either medical decision making or time.

CMS Updates and Finalizes HCPCS Codes G2211 and G2212

CMS uses feedback from the proposed rule to update the definition of HCPCS add-on code G2211 (referred to in the proposed rule as GPC1X) to add additional clarity and assume utilization of 90 percent of office/outpatient E/M visits during CY 2021.

CMS also finalizes separate payment for G2212 for prolonged office/outpatient E/M visits to clarify the times for which prolonged visits can be reported.

Services Similar to E/M are Revalued

CMS finalizes the revaluation of code sets that include, rely upon, or are analogous to office/outpatient E/M visits consistent with the increases in values we finalized for office/outpatient E/M visits for CY 2021:

• End-Stage Renal Disease (ESRD) Monthly Capitation Payment (MCP) Services
• Transitional Care Management (TCM) Services
• Maternity Services
• Cognitive Impairment Assessment and Care Planning
• Initial Preventive Physical Examination (IPPE) and Initial & Subsequent Annual Wellness Visits (AWV)
• Emergency Department Visits
• Therapy Evaluations
• Psychiatric Diagnostic Evaluations and Psychotherapy Services

Impacts to Specialties are Significant and Variable

CMS acknowledges in the final rule that proposed changes will have a significant impact for some specialties. These changes can largely be attributed to previously finalized policies for increases in valuation for office/outpatient E/M visits which constitute nearly 20 percent of total spending under the PFS. The Agency produces a Table 106 on pages 1521-1522 of the displayed rule that includes expected total payment and average change across services in a specialty and they note that the changes are budget neutral, meaning that there are increases and decreases. For example:

INCREASES	DECREASES
·         endocrinology (+16%)	·         chiropractor (-10%)
·         rheumatology (+15%)	·         radiology (-10%)
·         family practice (+13%)	·         nurse anesthetists (-10%)
·         hematology/oncology (+14%)	·         pathology (-9%)
·         allergy/immunology (+9%)	·         thoracic surgery (-8%)
·         urology (+8%)	·         cardiac surgery (-8%)
·         psychiatry (+7%)	·         physical/occupational therapy (-9%)
·         nephrologists (+6%)	·         emergency medicine (-6%)
·         neurology (+6%)	·         vascular surgery (-6%)
·         internal medicine (+4%)	·         orthopedic surgery (-4%)

Medicare Will Cover Additional Telehealth Services in 2021

In the April 2020 COVID-19 interim final rule (IFC), CMS added services to the Medicare telehealth list for the duration of the COVID-19 PHE. CMS estimates that 24.5 million of the 63 million Medicare beneficiaries utilized telehealth services since the passing of the IFC. CMS will make the following nine telehealth services permanent under Category 1:

• Group Psychotherapy (CPT code 90853)
• Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT codes 99334-99335)
• Home Visits, Established Patient (CPT codes 99347- 99348)
• Cognitive Assessment and Care Planning Services (CPT code 99483)
• Visit Complexity Inherent to Certain Office/Outpatient E/Ms (HCPCS code G2211)
• Prolonged Services (HCPCS code G2212)
• Psychological and Neuropsychological Testing (CPT code 96121)

Category 1, under the Medicare telehealth list, is for services such as consultations and office visits similar to those already on the telehealth list. Category 2 is for services that are not similar to those on currently on the telehealth list. With this final rule, CMS will create a new temporary Category 3, for services added to the Medicare telehealth list during the COVID-19 PHE. The following services will be added to the Medicare telehealth list under Category 3:

• Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT codes 99336-99337)
• Home Visits, Established Patient (CPT codes 99349-99350)
• Emergency Department Visits, Levels 1-5 (CPT codes 99281-99285)
• Nursing facilities discharge day management (CPT codes 99315-99316)
• Psychological and Neuropsychological Testing (CPT codes 96130-96133; CPT codes 96136-96139)
• Therapy Services, Physical and Occupational Therapy, All levels (CPT codes 97161-97168; CPT codes 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521-92524, 92507)
• Hospital discharge day management (CPT codes 99238-99239)
• Inpatient Neonatal and Pediatric Critical Care, Subsequent (CPT codes 99469, 99472, 99476)
• Continuing Neonatal Intensive Care Services (CPT codes 99478-99480)
• Critical Care Services (CPT codes 99291-99292)
• End-Stage Renal Disease Monthly Capitation Payment codes (CPT codes 90952, 90953, 90956, 90959, 90962)
• Subsequent Observation and Observation Discharge Day Management (CPT codes 99217; CPT codes 99224-99226)

These services will eventually need to meet the criteria under Categories 1 or 2 to be permanently added to the Medicare telehealth list. CMS previously proposed that it would not include some of these services temporarily included on the Medicare telehealth list due to the COVID-19 PHE as either Category 1 or Category 3 (e.g., ESRD monthly capitation payment codes, therapy services, etc.). However, in its final rule CMS includes larger list of services under the new Category 3. CMS is also commissioning a study of the remaining telehealth flexibilities that it did not add to the Medicare telehealth list in this rule. Telehealth services temporarily covered during the PHE will be covered through the end of the year that the PHE ends.

Furthermore, audio-only telehealth services will continue to be covered by Medicare on an interim basis. In this final rule, CMS establishes an interim final policy for additional coding and payment for extended audio-only assessment services. Accordingly, CMS establishes the following HCPCS code:

• G2252: Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services; established patients only; 11-20 minutes of medical discussion
• G2252 will be directly crosswalked to CPT code 99442. After the end of the PHE, there will be no additional payment for audio-only E/M visit codes.

Additionally, CMS will replace the current policy that limits follow-up nursing facility telehealth visits to every 30-days with every 14-days. Licensed health care professionals such as speech-language pathologists, physical and occupational therapists, clinical psychologists, and clinical social workers, will be able to continue to furnish remote evaluation services, virtual check-ins, and online assessments.

Through the waiver authority of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), CMS removed the geographic and site of service originating site restrictions for Medicare telehealth services. The final rule does not include any provisions to make these flexibilities permanent outside of rural areas because CMS is limited by statute and cannot permanently expand the list of telehealth providers. CMS believes that making these flexibilities permanent requires an act of Congress.

CMS Allows Direct Supervision using Interactive Technology

CMS finalizes its proposal to allow direct supervision using real-time, interactive audio and video technology through the end of the calendar year in which the COVID-19 public health emergency (PHE) ends. This policy is consistent with that adopted in the COVID-19 interim final rule with comment (85 FR 19245).

CMS Expands Access to Care Coordination Management Services and Remote Physiologic Monitoring

CMS aims to improve payment for care management services through payment changes to the following services:

• Remote physiologic monitoring (RPM),
• Transitional care management (TCM), and
• Psychiatric collaborative care model (CoCM)

CMS Expands Access to Remote Physiologic Monitoring Services

In prior rulemakings, CMS added reimbursement for development and management of a plan of treatment based upon patient physiologic data in 2020, and for 2021 is adding payment for prolonged face-to-face and/or non-face to face E/M work related to an office/outpatient E/M  visit in addition to their other care management codes.

In this rule, CMS finalized its proposals to expand access to remote physiologic monitoring (RPM) services:

• After the COVID-19 PHE ends:
  • There must be an established patient-physician relationship for RPM services to be furnished; and
  • 16 days of data each 30 days must be collected and transmitted to meet the requirements to bill CPT codes 99453 and 99454.
• Consent to receive RPM services may be obtained at the time that RPM services are furnished.
• Auxiliary personnel may provide services described by CPT codes 99453 and 99454 incident to the billing practitioner’s services and under their supervision. Auxiliary personnel may include contracted employees.
• The medical device supplied to a patient as part of RPM services must be a medical device as defined by Section 201(h) of the Federal Food, Drug, and Cosmetic Act, that the device must be reliable and valid, and that the data must be electronically (i.e., automatically) collected and transmitted rather than self-reported.
• Only physicians and non-physician practitioners who are eligible to furnish E/M services may bill RPM services.
• RPM services may be medically necessary for patients with acute conditions as well as patients with chronic conditions.
• For CPT codes 99457 and 99458, an “interactive communication” is a conversation that occurs in real-time and includes synchronous, two-way interactions that can be enhanced with video or other kinds of data as described by HCPCS code G2012.  We further clarified that the 20-minutes of time required to bill for the services of CPT codes 99457 and 99458 can include time for furnishing care management services as well as for the required interactive communication.

CMS Expands Transitional Care Management Billing

CPT Codes 99495 and 99496 describe management of a patient’s transition from acute care or certain outpatient stays to a community setting, with a face-to-face visit, once per patient within 30 days post-discharge. CMS finalized its proposal to remove 14 codes from its list of codes that cannot be billed concurrently with the transitional care management codes because of potential duplication of those services. CMS is also permitting the code for complex chronic care management services to be billed concurrently with the TCM codes when appropriate.

CMS Creates New Code for Behavioral Health Management Under its Psychiatric Collaborative Care Model (CoCM)

Under its Psychiatric Collaborative Care Model, CMS finalized its proposal to add a new code to permit billing for shorter increments of behavioral health care manager time than under the codes currently used to bill for these services. The new code would describe initial or subsequent psychiatric collaborative care management, first 30 minutes in a month of behavioral health care manager activities, in consultation with a psychiatric consultant, and directed by the treating physician or other qualified health care professional.  The new code is HCPCS code G2214 (Initial or subsequent psychiatric collaborative care management, first 30 minutes in a month of behavioral health care manager activities, in consultation with a psychiatric consultant, and directed by the treating physician or other qualified health care professional).

CMS Expands Flexibility for Teaching Hospitals

Physicians at Rural Teaching Hospitals will be Permitted to Use Telehealth with Residents

CMS is finalizing its proposal to allow physicians teaching residents in a teaching hospital to use telehealth technology to provide the necessary direction, management and review in rural areas. Teaching physicians will be able to bill for their services provided virtually involving residents only when the services are furnished in residency training sites that are located outside of an OMB-defined metropolitan statistical area (MSA).  For all other settings, CMS is not permanently finalizing their teaching physician virtual presence policies.

Residents Receive Expanded Responsibilities

In addition, in response to the PHE, CMS revised its policy regarding residents providing services outside their GME program. During the PHE, residents can provide inpatient services within their program’s hospital and be considered separately billable physicians’ services under the PFS. CMS is finalizing this moonlighting policy for the duration of the PHE only.

Also, in response to the PHE, CMS expanded the “primary care exception” to allow residents to perform all levels of office/outpatient evaluation and management (E/M) included in the table below. In the Final rule, CMS is finalizing allowing Medicare to permanently pay teaching physicians when the resident provides expanded services under the primary care exception, but only for locations outside of a metropolitan statistical area (MSA) and only for the CPT codes 99421-99423, 99452, and HCPCS codes G2010 and G2012 to preserve the original intent of the primary care exception, which is limited to services of lower and mid-level complexity.

 

Codes	Service
CPT codes 99204 & 99205	Office or other outpatient visit for evaluation of a new patient
CPT codes 99214 & 99215	Office or other outpatient visit for the evaluation and management of an established patient
CPT codes 99495 & 99496	Transitional care management services with required elements
CPT codes 99421, 99422 & 99423	Online digital evaluation and management service for established patient
CPT 99452	Interprofessional telephone/internet/electronic health record referral service
HCPCS G2012	Brief communication technology-based service, e.g. virtual check-in, provided to established patient
HCPCS G2010	Remote evaluation of recorded video and/or images submitted by an established patient

 

CMS Does Not Finalize Coding for 505(b)(2) Products but Indicates Agency will Further Consider the Issue

CMS had proposing to codify its existing policy to continue assigning certain section 505(b)(2) drug products to existing multiple source drug HCPCS codes if the product is described by such a code, based on the products description, including labeling and uses. However, due to feedback from public comments, CMS is not finalizing the proposal. Many commenters were not supportive of the policy and some requested more details about CMS’ proposed approach. CMS says that they are delaying a decision and will further consider the issue, meaning it could arise in future rulemaking.

CMS Finalizes the Removal of Six National Coverage Determinations

CMS finalizes the removal of six of the nine proposed outdated or obsolete National Coverage Determinations (NCDs) effective January 2021. As science and technology evolve, CMS feels it is important to regularly evaluate coverage and broad-non-coverage NCDs to allow for updated NCDs and allow stakeholders to provide new evidence for consideration. The six NCDs for removal are:

• Extracorporeal Immunoadsorption (ECI) using A Columns;
• Electrosleep Therapy;
• Implantation of Gastroesophageal Reflux Device;
• Abarelix for the Treatment of Prostate Cancer;
• Magnetic Resonance Spectroscopy; and
• FDG PET for Inflation and Infection.

However, in response to public comments, CMS is not finalizing the removal of Apheresis, Histocompatibility Testing, or Cytogenetic Studies but will consider updating these NCDs or proposing their removal in future rulemaking.

Scope of Practice Changes Finalized for Multiple Provider Types

The CY 2021 PFS final rule finalizes adjustments to the scope of practice rules for various providers, including nurse practitioners, pharmacists, and therapy assistants.

CMS makes permanent the May 1st COVID-19 IFC which authorizes nurse practitioners (NPs), clinical nurse specialists (CNSs), physician assistants (PAs), and certified nurse-midwives (CNMs) to supervise the performance of diagnostic tests within their scope of practice and state law. In this final rule, CMS adds certified registered nurse anesthetists (CRNAs) to this list of nonphysician practitioners.

The maintenance therapy policy in the May 1st COVID-19 IFC authorizing physical therapists (PTs) and occupational therapists (OTs) to delegate performance of clinically appropriate maintenance therapy services to a therapy assistant, will also become permanent, aligning the policy with other rehabilitative services.

CMS reiterates the clarification initially made in the May 8th, 2020 COVID-19 IFC that pharmacists fall within the regulatory definition of auxiliary personnel under the “incident to” regulations. As such, pharmacists may provide services in connection to the overall physician’s treatment plan under the appropriate level of supervision for services, not under the Medicare Part D benefit.

CMS also finalizes broad modifications to the medical record documentation requirements for physicians and certain nonphysician practitioners (NPPs), allowing physicians and NPPs to review and verify documentation entered into the medical record by a member of the medical team for their services with the stipulation that they are paid under the PFS. This final rule further clarifies that students working under these practitioners, who furnish and bill Medicare for their services, can also document medical records as long as the billing practitioner reviews, signs, and dates it.

CMS Finalizes Updates for Quality Payment Program, Including New Reporting Pathway for APM Participants

In the annual PFS rulemaking, CMS includes its proposals for the Quality Payment Program (QPP), which includes two tracks: Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). MIPS includes four performance categories: quality, cost, improvement activities, and promoting interoperability.

In CY 2020 rulemaking, CMS finalized creation of the MIPS Value Pathways (MVPs), a reporting option for MIPS that the agency believes will provide a more cohesive participation experience. This would be accomplishing by aligning activities from the four MIPS performance categories around a certain specialty, medical condition, or patient population. Stakeholders will be able to submit MVP candidates and CMS intends to collaborate with clinicians in developing MVPs. CMS originally intended to begin the transition to the MVPs in 2021, but due to the COVID-19 pandemic, this transition has been delayed until at least 2022.

Also in response to the COVID-19 pandemic, the maximum number of points available for the complex patient bonus will be increased for the 2020 performance period/2022 MIPS payment year due to the increase in patient complexity from the PHE. This increase will last for one year.

For performance year 2021, CMS is finalizing the proposal to eliminate the APM scoring standard to provide APM participants with additional flexibility in how they participate in MIPS. However, CMS declined to finalize the proposal to lower the 2021 performance year/2023 payment year performance threshold to 50 points, instead leaving it at the previously finalized 60 points. For MIPs eligible clinicians in the 2021 performance year/2023 payment year, CMS is finalizing the following weights for the four MIPS categories:

• Cost: 20 percent
• Quality: 40 percent
• Promoting Interoperability: 25 percent
• Improvement Activities: 15 percent

CMS notes in the final rule that based on current law, the weight of the cost performance category will increase to 30 percent for the 2022 performance year/2024 payment year. The quality category will then see a decrease in its weight to 30 percent in the 2024 payment year.

A total of 209 quality measures will be included for the 2021 performance year. Services provided via telehealth will be included in quality and cost measurement.

New Reporting Pathway for APMs Finalized

CMS is moving forward with creation of the APM Performance Pathway (APP), a voluntary pathway designed to provide a predictable reporting standard, reduce reporting burden, and encourage APM participation. This new reporting pathway will begin January 1, 2021 for MIPS eligible clinicians that participate in any MIPS APM. The APP will have a fixed set of measures for each performance category and all APM participants reporting through the APP will earn a score of 100% in 2021.

APP participants will have the cost performance category waived. CMS notes that the APM entities are already subject to cost performance assessment under the APM design. For the improvement activities category, each MIPS APM will receive a score and this score will be applied to participant MIPS eligible clinicians that choose to report through the APP. The weight of each performance category for APM participants reporting through the APP is:

• Cost: 0 percent
• Quality: 50 percent
• Promoting Interoperability: 30 percent
• Improvement Activities: 20 percent

Accountable Care Organizations (ACOs) that participate in the Medicare Shared Savings Program (MSSP) will be required to reporting using the APP in order to assess their quality performance for that program. However, MIPs eligible clinicians that participate in these ACOs may choose to report whether to report through the APP or outside of it, similar to the choice other MIPS APM participants will be able to make.

CMS Improves Alignment Between Promoting Interoperability and MIPS

In the CY 2020 PFS final rule, CMS established that Medicaid Eligible Professionals (EPs) are required to report on any six eCQMs that are relevant to the EP’s scope of practice. They also adopted the Merit-based Incentive Payment System (MIPS) requirement that EPs report on at least one outcome measure. If no outcome or high priority measure is relevant to a Medicaid EP’s scope of practice, then an EP may report on any six eCQMs that are relevant. In the CY 2021 PFS final rule, CMS amends the list of available eCQMs for the CY 2021 performance period (2023 payment period). Though some commenters asked if CMS would allow the option to report using 2020 specifications or to extend deadlines, the Agency noted the flexibility in reporting and that the updated measures use the best available evidence. Additionally, CMS establishes that the eCQM reporting period in 2021 for EPs in the Medicaid Promoting Interoperability Program will be a minimum of any continuous 90-day period within CY 2021.

CMS Attempts to Reduce Reporting Burden in Medicare Shared Savings Program

The Medicare Shared Savings Program was established to facilitate coordination among health care providers to improve the quality of care for Medicare fee-for-service (FFS) beneficiaries and to reduce the expenditure growth under Medicare Parts A and B. The Program allows an Accountable Care organization (ACO) to receive a shared saving payment if it meets the specified quality and savings criteria, while the participating suppliers and providers continue to receive traditional Medicare FFS payments.

CMS is finalizing changes to the Medicare Shared Saving Program (MSSP) quality performance standard and quality reporting requirements for the performance years beginning on January 1, 2021 in an effort to reduce burden on ACOs and allow them to focus on patient outcomes. The quality performance standard is the overall standard that an ACO must meet to qualify to share in savings.

The quality performance standard is currently based on the level of full and complete reporting for the ACO’s first performance year under the Shared Savings Program. In subsequent years, quality measures are scored as pay-for-performance. In the CY 2020 PFS proposed rule, CMS sought comment on aligning the Shared Savings Program quality reporting requirements and scoring methodology with that of MIPS, which suggested a higher standard for eligibility for shared savings for ACOs.

CMS believes that the Alternative Payment Model Performance Pathway (APP) under the Quality Payment Program (QPP) with a narrower measure set is appropriate to assess the quality performance of ACOs participating in the Shared Savings Program. The MIPS Quality performance category score will be calculated for ACOs based on MIPS benchmarks, which are used for other non-ACO group and individual reporters.

Therefore, for performance year 2021, ACOs must report quality data via the APP, and can choose to report either the ten measures under the CMS Web Interface or the three eCQM/MIPS CQM measures. ACOs will also be required to field the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS survey, and CMS will calculate two measures using the administrative claims data.

For performance year 2022 and all subsequent performance years, ACOs will be required to actively report quality data on the three eCQM/MIPS CQM measures through the APP. ACOs will only need to report one set of quality metrics to meet requirements for MIPS and MSSP.

CMS Raises ACO Performance Standard

CMS is finalizing its revisions to the Shared Savings Program Quality Performance Standard, allowing ACOs to meet the standard if they achieve a quality performance score that is equal to the 30th percentile or higher across all MIPS quality performance categories for performance years 2021 and 2022. For performance years 2023 and all subsequent performance years, ACOs must achieve a quality performance score at the 40th percentile mark or higher.

In the rule, CMS also strengthens the policies for compliance with the quality performance standard by broadening the conditions under which CMS may terminate an ACO’s participation agreement when an ACO demonstrates a pattern of failure to meet the quality performance standard. CMS plans to monitor and address any continued noncompliance with the quality performance standard and proposes that ACOs with a pattern of failing to meet this standard will be terminated from the program.

CMS is also finalizing changes to the methodology for determining shared savings and losses based on ACO quality performance, updating the process to validate ACO quality reporting data, and updating the extreme and uncontrollable circumstance policy as it relates to quality performance.

No Data Reporting or Payment Reductions for CDLTs in CY 2021

Based on the CARES Act, CMS is finalizing changes to data reporting and payment requirements for the Medicare Clinical Laboratory Fee Schedule (CLFS). The next data reporting period is January 1, 2022 through March 21, 2022 for clinical diagnostic laboratory tests (CDLTs). The data reported in this period will be based on data collected from 2019. Additionally, there will a zero percent payment reduction for CDLTs in CY 2021. For CY 2022 through 2024, payment for CDLTs may not be reduced by more than 15 percent in comparison to the amount established for the year prior.

Payment for Specimen Collection for COVID-19 CDLTs

In the proposed rule, CMS solicited comments on HCPCS codes G2023 and G2024 for use by independent laboratories billing Medicare for the nominal specimen collection for COVID-19 testing for the duration of the public health emergency established in the March 31^st interim final rule. Several stakeholders commented requesting that CMS permanently extend payment for specimen collection for COVID-19 tests. CMS did not make any changes to payment for specimen collection but will consider stakeholder responses for future rulemaking and guidance.