Compliance Monitor (03/27/2025)
Your source for federal updates
March 2025 Compliance Activity
| The completed form must be posted for three months, from February 1 until April 30 The completed form must be submitted to OSHA by early March | OSHA Form 300-A form Form 300-A is the Summary of Work-Related Injuries and illnesses At the end of each calendar year, Form 300- A must be completed and certified by a company executive as correct and complete and posted in the workplace annually, where notices to workers are usually posted. Establishments under Federal OSHA jurisdiction can use the ITA Coverage Application to determine if they are required to electronically report their injury and illness information to OSHA. Establishments under State Plan jurisdiction should contact their State Plan. https://www.osha.gov/news/newsreleases/tr ade/01092023 Form 300-A https://www.osha.gov/recordkeeping/forms |
| March 1, 2025, if any breaches in 2024 | HIPAA Breach Reporting HIPAA-covered entities and their business associates are required annually to notify the Office for Civil Rights (OCR) of breaches of unsecured protected health information (PHI) that affect under 500 individuals. Report breaches of unsecured protected health information that affect fewer than 500 individuals utilizing the web portal in the link. Submitting a notice of breach to the HHS secretary https://www.hhs.gov/hipaa/for- professionals/breach- notification/breach- reporting/index.html |
| Usually posted in late March – early April | CMS Hospice Payment Update Rule (Proposed Rule) Usually posted in late March – early April Annual FY issuance Includes proposed annual payment update and quality program information Other proposed regulations or changes to standing regulations may be included with the opportunity for comments (as applicable) |
| Posted in mid-March | MedPAC report to Congress Annual issuance Includes data analysis of Medicare hospice utilization and spending and recommendations to Congress There is a specific home health and hospice chapter |
| March 3, 2025 | Section 1557 Requirement and Provision must be implemented § 92.9 Training – https://www.federalregister.gov/documents/2024/05/06/2024-08711/nondiscrimination-in-health-programs-and-activities#h-62 § 92.210(b), (c) Use of patient care decision support tools – page 37701 https://www.govinfo.gov/content/pkg/FR-2024-05-06/pdf/2024-08711.pdf |
| Extension expires Mar 31, 2025 | Telehealth extension Removing geographic requirements and expanding originating sites for telehealth services (42 USC § 1395m(m)); Telehealth services can be delivered to any location in the U.S., including the home of an individual. Extending the use of telehealth to conduct face-to-face encounters prior to recertification of eligibility for hospice care (42 USC § 1395f(a)(7)(D)(i)(II)); Telehealth encounters prior to recertification of eligibility for hospice care are covered and reimbursable. |
| April 2025 Preview | |
| Implements with April decedents | Update hospice CAHPS survey implementation Updated QAG V11.0 Survey Materials CHAP blog – Countdown to the Updated Hospice CAHPS Survey |
CDC Respiratory Illnesses Data Channel
Overall respiratory illness activity in the United States
https://www.cdc.gov/respiratory-viruses/data/index.html
Top Items
MedPAC Posts March 2025 Report to the Congress: Medicare Payment Policy
In this report, MedPAC provides a status report on MA, including recent trends in enrollment, plan offerings, and Medicare’s payment to plans, and we discuss issues such as MA coding intensity, favorable selection, and market concentration. They also provide a status report on Part D that, in addition to providing information on recent trends in enrollment and plan offerings, describes the expected effects of significant changes happening in 2025, as implementation of the Inflation Reduction Act of 2022 continues.
MedPAC Home Health Recommendations
Review indicates that FFS Medicare’s payments for home health care are substantially in excess of costs. Home health care can be a high-value benefit when it is appropriately and efficiently delivered, but these excess payments diminish that value. The Commission recommends that, for calendar year 2026, Congress should reduce the 2025 base payment rate by 7 percent.
MedPAC Hospice Recommendations
Based on the positive indicators of payment adequacy and the strong FFS Medicare margins, current payment rates appear sufficient to support the provision of high-quality care without an increase to the payment rates in 2026. The Commission recommends that Congress eliminate the update to the hospice base payment rates for fiscal year 2026.
CMS Rescinds Memo – The Importance of Timely Use of COVID-19 Therapeutics
CMS is rescinding this memo (QSO-23-03-All), effective on 01/20/2025 as referenced in Executive Order 13997 on 3/14/2025.
Memo Summary – Providers and suppliers, especially those delivering care in congregate care settings, should ensure their patients and residents are protected against transmission of COVID-19 within their facilities, as well as receiving appropriate treatment when tested positive for the virus. Further, all providers and suppliers should continue to implement appropriate infection control protocols for COVID-19.
This memo discusses the importance of the timely use of available COVID-19 therapeutics, particularly for high-risk patients who test positive for the virus.
Hospice Provider Updates
Telehealth for Hospice F2F is Extended to September 30, 2025
Congress has passed the Full-Year Continuing Appropriations and Extensions Act 2025 (FY2025), which allowed for continuation of the utilization of telehealth for completion of the face-to-face visit for hospice recertification. See text from the legislation below
“Extending use of telehealth To conduct face-to-Face encounter prior to recertification of eligibility for hospice care.—Section 1814(a)(7)(D)(i)(II) of the Social Security Act (42 U.S.C. 1395f(a)(7)(D)(i)(II)) is amended by striking “ending on March 31, 2025” and inserting “ending on September 30, 2025.”
FY 2026 Hospice Wage Index, Payment Rate Update, and Quality Reporting Requirements (CMS-1835) – Update
The FY 2026 Hospice Wage Index, Payment Rate Update, and Quality Reporting Requirements proposed rule is still at the Office of Management and Budget for review. Please watch CHAP communication for more information when the rule posts to the Federal Register.
Home Health Provider Updates
Reminder – Transition to All-Payer OASIS Data Collection and Submission
Collect and submit OASIS data for all patients with any pay source who are not exempt from OASIS data collection and who begin receiving home health care services with an OASIS SOC M0090 date on or after July 1, 2025. See the CMS Fact Sheet
Federal Reports
GAO-25-108172Published: Mar 11, 2025
Improper payments and fraud are long-standing and significant problems in the federal government. Since fiscal year 2003, cumulative improper payment estimates by executive branch agencies have totaled about $2.8 trillion. In fiscal year 2024, federal agencies estimated $162 billion in improper payments, representing 68 programs, a small subset of all federal programs. The fiscal year 2024 estimate is a decrease of about $74 billion from the prior year. The reduction in estimated improper payments is largely attributable to the completion or winding down of certain COVID-19 programs. About 75 percent ($121 billion) of the government-wide total of estimated improper payments that agencies reported for fiscal year 2024 is concentrated in five program areas
OIG Posts Medicaid Fraud Control Units Annual Report: Fiscal Year 2024
Medicaid Fraud Control Units (MFCUs or Units) investigate and prosecute Medicaid provider fraud and patient abuse or neglect. The Department of Health and Human Services Office of Inspector General (OIG) is the designated Federal agency that oversees and annually recertifies and approves Federal funding for each MFCU. For this data snapshot, the OIG analyzed the annual data on case outcomes (such as convictions; civil settlements and judgments; and recoveries) that 53 MFCUs submitted to OIG for fiscal year (FY) 2024, as well as other historical data. Those MFCUs operated in all 50 States, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands.
All Providers
CMS Extends Registration Deadline for Public Engagement Events: Medicare Drug Price Negotiation Program IPAY 2027
CMS is extending the registration deadline to March 19, 2025, for public engagement events for the second cycle of negotiations.
CMS will host a series of public engagement events this spring as part of the Medicare Drug Price Negotiation Program. The virtual public engagement events will provide an opportunity for patients, beneficiaries, caregivers, consumer and patient organizations, and other interested parties, such as clinicians and researchers, to share input relevant to the drugs selected for the second cycle of negotiations.
Dates: The public engagement events will be held April 16 – April 30, 2025. The deadline to register has been extended and will now be open until March 19, 2025.
Attendance: Anyone from the public may attend the town hall meeting livestream as a listener. Registration is not required, and the link to the livestream will be available here on April 30, 2025. Accommodation for people with disabilities and language assistance (e.g., interpretation) may be available.
Those who wish to make a public statement in the town hall meeting or to participate in a private roundtable event should register for the opportunity to speak at the public engagement events. Additional information to register for the events can be found here. For more information about the public engagement events, please see the Frequently Asked Questions document linked here.
If you are selected to speak at the event for which you registered, you will have 4 days after receiving the confirmation email to confirm your availability to participate at the selected event date and time, and any language interpretation services you need.
The public engagement events are subject to change, including postponement and/or cancellation.
Additional information on the public engagement events can be found here. Additional information about the Medicare Drug Price Negotiation Program can be found here.
ICD-10 Coordination & Maintenance Committee: Submit Procedure Code Comments by April 18
CMS won’t present Spring 2025 ICD-10-PCS procedure code topics during a public meeting. Instead, we’re soliciting public comments by email, and we’ll post materials, Q&As, and related documents. See ICD-10 Coordination and Maintenance Committee Meeting Materials for more information.
The deadline to submit comments on procedure code topics for an October 1, 2025, implementation is April 18. Send your questions or comments to ICDProcedureCodeRequest@cms.hhs.gov.
Note: If you have questions about diagnosis code topics, contact nchsicd10cm@cdc.gov.
Medicare Coverage of Diabetes Supplies — Revised
CMS added coverage information (PDF) for continuous glucose monitors.
CMS Innovation Center Announces Model Portfolio Changes to Better Protect Taxpayers and Help Americans Live Healthier Lives
The CMS Innovation Center announced changes to its model portfolio to align with its statutory mandate and strategic goals.
The Center regularly assesses and may amend model activities in response to a model’s projected savings, quality outcomes data, legal compliance, operational feasibility and gaps in expected versus actual impact.
What’s changing
Models Identified to End Early (Original Performance Period)
- Maryland Total Cost of Care (2019 – 2026)
- Primary Care First (2021 – 2026)
- ESRD Treatment Choices (2021 – 2027; will propose termination through rulemaking)
- Making Care Primary (2024 – 2034)
Additionally, the CMS Innovation Center is considering options to reduce the size of Integrated Care for Kids (2020 – 2026).
Further, the CMS Innovation Center will no longer pursue two previously announced but not yet implemented models given the flexibility provided by President Trump’s recission of Executive Order 14087 on January 20, 2025.
- Accelerating Clinical Evidence
Next Steps
Participants should expect follow-up communication from their models with timelines, technical assistance and other information regarding the wind-down and close-out.
The Innovation Center will publish final evaluation reports from models ending to inform participants and other stakeholders of the important findings and insights about the tested approaches to value-based care.
The Center will share more of its new strategic vision to empower Americans to live healthier lives while protecting taxpayers in the near future.
Read more:
CMS Takes Aim to Reduce Improper Enrollments and Promote More Affordable Health Insurance Marketplaces for Millions of Consumers
CMS released a proposed rule to address the troubling amount of improper enrollments impacting Affordable Care Act (ACA) Health Insurance Marketplaces across the country. CMS’ 2025 Marketplace Integrity and Affordability Proposed Rule includes proposals that take critical and necessary steps to protect people from being enrolled in Marketplace coverage without their knowledge or consent, promote stable and affordable health insurance markets, and ensure taxpayer dollars fund financial assistance only for the people the ACA set out to support.
CMS’ proposed rule aims to take decisive action to root out these improper enrollments from the ACA’s Health Insurance Marketplaces. It is estimated that, if fully implemented, these actions will reduce improper federal spending on advance payments of the premium tax credit by $11 billion to $14 billion in 2027.
The rule proposes changes to address improper enrollments, to help people maintain continuous coverage, and to improve the risk pool. CMS expects these proposals will provide premium relief to middle class families who do not qualify for federal premium subsidies and reduce the burden of the ACA premium subsidy expenditures to the federal taxpayer.
View the 2025 Marketplace Integrity and Affordability Proposed Rule (CMS-9884-P) here: https://www.cms.gov/files/document/MarketplacePIRule2025.pdf
Medicare Shared Savings Program: Application Deadlines for January 1, 2026, Start Date
Accountable care organizations (ACOs): See Medicare Shared Savings Program Application Types & Timeline to learn about key dates for a January 1, 2026, start date. CMS will accept applications starting May 29 through the ACO Management System. Apply no later than June 12 at noon ET.
2025 CMS Conference for Building a Healthier America
The CMS Conference for Building a Healthier America, scheduled for April 23-24, 2025, has been postponed. Future conference dates will be announced at a later time.
Bacterial Culture Lab Test: Prevent Claim Denials
In 2023, the improper payment rate for bacterial culture lab tests was 15.1%, with a projected improper payment amount of $9.6 million (see 2023 Medicare Fee-for-Service Supplemental Improper Payment Data (PDF), Appendices E and G). Learn how to bill correctly for these services. Review the Bacterial Culture Lab Tests provider compliance tip for more information, including denial reasons and how to prevent them.
Complying with Medical Record Documentation Requirements — Revised
Learn what’s changed (PDF). CMS added:
- Documentation guidelines for medical services
- Resources for Medicare documentation requirements
Update your link to this publication if you bookmarked it.
Claims, Prices & Codes
Medicare Part B Drug Pricing Files & Revisions: April Update
Learn about quarterly updates to the following average sales price and not otherwise classified pricing files:
- April 2025
- January 2025
- October 2024
- July 2024
- April 2024
See the instruction to your Medicare Administrative Contractor (PDF).
CMS Resources
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