Compliance Monitor (01/10/2025)

Overall respiratory illness activity in the United States 

What to know 

• As of January 3, 2025, the amount of acute respiratory illness causing people to seek healthcare is at a high level and continues to increase nationally. 

• COVID-19 activity is increasing in most areas of the country. 

• Seasonal influenza activity continues to increase and is elevated across most of the country. 

• RSV activity is very high in many areas of the country, particularly in young children. 

• The community snapshot signifies activity levels using the following: minimal, low, moderate, high, very high. 

https://www.cdc.gov/respiratory-viruses/data/index.html

On 1/7/2025, the President declared that a major disaster exists in the State of California and ordered Federal aid to supplement State, tribal, and local recovery efforts in the areas affected by wildfires and straight-line winds beginning on January 7, 2025, and continuing. 

The President’s action makes Federal funding available to affected individuals in Los Angeles County. 

Public comments on the NPRM are due on March 4, 2025.  

CMS is terminating the Medicare Advantage (MA) Value-Based Insurance Design (VBID) model at the end of 2025 due to the model’s substantial and unmitigable costs to the Medicare Trust Funds. Excess costs to the Medicare Trust Funds of this magnitude — $2.3 billion in Calendar Year (CY) 2021 and $2.2 billion in CY 2022 associated with the VBID model, based on the prior and forthcoming evaluation reports, respectively — are unprecedented in CMS Innovation Center models.  

CMS is making this announcement more than a year before the termination effective date to provide ample time for MA plans and their partner organizations to prepare for CY 2026 in ways that best support their enrollees’ needs.  

As required by the HH Conditions of Participation (COP), an OASIS privacy notice must be provided to all patients for whom the OASIS data is collected. Due to the transition to OASIS data collection for all patients, regardless of payer, effective January 1, 2025, Home Health Agencies should only provide patients with the CMS Privacy Act Statement and Attachment A – Statement of Patient Privacy Rights. These forms are available on the Home Health Agency Center webpage in the OASIS section. Both documents are available in English and Spanish. 

Beginning January 1, 2025, and until further notice, Attachment C – Notice About Privacy for Patients Who Don’t Have Medicare or Medicaid should not be provided to patients. 

For this refresh, Home Health (HH) Outcome and Assessment Information Set (OASIS) measures have been updated. 

For additional information, please see the HH Quality Reporting Training webpage and the Home Health Data Submission Deadlines webpage.  

In 2023, the improper payment rate for infusion pumps and related drugs was 12.5%, with a projected improper payment amount of $80.9 million (see 2023 Medicare Fee-for-Service Supplemental Improper Payment Data (PDF), Appendices D, G, K, and N). Learn how to bill correctly for these supplies and services. Review the Infusion Pumps & Related Drugs provider compliance tip for more information, including: 

• Billing codes 

• Denial reasons 

• External and implantable infusion pump: covered indications 

• Refill and documentation requirements 

Learn what’s changed (PDF). CMS added: 

• Claims processing instructions for the intravenous immune globulin (IVIG) permanent benefit, including place of service code 04 

• Coverage information 

• Q2052 payment rate and time increment table for CY 2025 

• New IVIG J-code for CY 2025 

On January 27, 2025, CMS will include a new product category on the electronic CMS-855S DMEPOS Enrollment Form for multi-function respiratory devices (excluding ventilators). 

You must be an enrolled DMEPOS supplier to get Medicare payment for furnishing these products. 

Starting January 27, 2025, if you enroll in Medicare to supply these DMEPOS products or want to add them to your current enrollment: 

• If you submit an online application using PECOS, report the product in Section 2  

• If you enroll using a paper application, you must also submit a letter stating that you want to supply these products; we’re working to update this application 

CMS updated the Part B payment amounts for CY 2025 preventive vaccine administration for: 

• COVID-19 

• Flu 

• Hepatitis B 

• Pneumococcal 

The update reflects: 

• Annual increase in the Medicare Economic Index 

• Geographically-adjusted vaccine administration rates for HCPCS codes G0008, G0009, G0010, 90480, and M0201 

• Payment rates for administering Part B preventive vaccines in the patient’s home 

More Information: 

• CY 2025 Physician Fee Schedule final rule 

• Vaccine Pricing webpage 

• Preventive Services webpage 

• Instruction to your Medicare Administrative Contractor (PDF) 

Learn about quarterly updates to the following average sales price and not otherwise classified pricing files: 

• January 2025 

• October 2024 

• July 2024 

• April 2024  

• January 2024 

More Information: 

• Press release 

• Instruction to your Medicare Administrative Contractor (PDF) 

CMS released data from the Accountable Health Communities Model, available to researchers through the CMS Research Data Assistance Center or ResDAC. The Research Identifiable File features beneficiary-level screening and navigation information. 

This data release is part of the CMS Innovation Center Model Data Sharing (CMDS) Participation Data Initiative. Files are updated on a quarterly basis. 

For information, please visit the CMDS Participation Data Initiative page 

In light of Thursday’s National Day of Mourning to honor President Jimmy Carter, we’ve postponed our Call for Proposals webinar to Tuesday, January 14, at 2 p.m. ET. 

The Call for Proposals webinar will provide information about the proposal submission process and key dates for the Centers for Medicare & Medicaid Services’ 2025 Health Equity Conference: Building a Healthier America. Following the presentation, we will answer questions from attendees as time permits. To attend, please register here. 

Due to the webinar’s postponement, we have extended the proposal submission deadline. Proposal submissions for the conference will now remain open through Tuesday, January 21, at 5 p.m. PT. Information and guidelines for submitting proposals, including important deadlines, can be found on the conference website. 

We hope you’re able to join us for the webinar during this new time on Tuesday, January 14, at 2 p.m. ET, and we look forward to receiving your proposal submission! 

Please visit https://www.cmshealthequitycon.com/ for more information.  

2025 CMS Quality Conference: Elevating Quality—Advancing Optimal Health for Individuals, Families, Caregivers, Clinicians and Communities, March 17-19, 2025, in Baltimore, MD. 

Registration (in-person and virtual) and hotel room blocks open February 3.  

Explore Eight Unique Tracks Across Three Informative Days 
Get ready to explore a diverse range of topics, including:  

• Advancing Health Equity   

• Collecting and Utilizing Quality Data   

• Engaging Partners and Communities   

• Integrating Behavioral and Physical Healthcare   

• Cultivating Healthcare System Resiliency and Readiness   

• Promoting High Reliability and Quality Improvement   

• Embracing Emerging New Technology and Innovation   

• Improving Patient Safety  

Stay tuned for in-person and virtual registration information as we get ready to advance optimal health together.