CMS Innovation Center Highlights
The CMS Innovation Center has had a busy start to 2025! Find CMS Innovation Center news and information at https://www.cms.gov/priorities/innovation/overview.

Noninvasive Positive Pressure Ventilation (NIPPV) in the Home for the Treatment of Chronic Respiratory Failure Consequent to COPD
This final NCD provides coverage of RADs for the treatment of chronic respiratory failure that often accompanies COPD. In addition, for the first time, Medicare establishes coverage criteria for HMV for patients with COPD.  For all other patient indications not included within the NCD, the MACs have authority to decide coverage.

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NCCI Third Quarter Edit Files
Get the National Correct Coding Initiative (NCCI) third quarter edit files effective July 1, 2025, on these Medicare NCCI webpages: 

• Medicare NCCI Procedure to Procedure (PTP) Edits 
• Medicare NCCI Medically Unlikely Edits (MUEs) 
• Medicare NCCI Add-on Code Edits 

FY 2026 ICD-10 codes
Get FY 2026 ICD-10 codes effective for patient discharges and encounters on or after October 1, 2025, here.

Providers Accepting CHAMPVA: You Must Enroll in EFT to Get Paid
If you treat patients who are covered by the Civilian Health and Medical Program of the Department of Veterans Affairs (CHAMPVA), you must sign up for direct deposit (electronic funds transfer (EFT)) to get paid. Getting paid by EFT isn’t optional, it’s a federal requirement.

Enrolling in EFT helps keep CHAMPVA claim payments secure, efficient, and compliant and protect Veterans’ family members’ access to benefits.

2 steps to enroll in EFT

1. Visit the VA Financial Services Center Customer Engagement Portal
2. Complete the Payment Account Setup webform; call Financial Services Center customer support at 877-353-9791 for help

RHC & FQHC Care Coordination Services: HCPCS Code G0511 Deadline Extended to September 30
Starting January 1, 2025, CMS requires Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) to report individual CPT and HCPCS base and add-on codes for care coordination service instead of reporting HCPCS code G0511. We allowed additional time for you to make this change to your billing systems and continue billing G0511 until July 1, 2025. Now, the deadline is extended to September 30. After this date, you will no longer be able to bill for HCPCS code G0511.

More Information

• RHC Center webpage, including list of CY 2025 payment rates for care coordination
• FQHC Center webpage, including list of CY 2025 payment rates for care coordination
• CY 2025 Physician Fee Schedule final rule

Medical Education: Submit No-Pay Bills for Programs of All-Inclusive Care for the Elderly
Programs of All-Inclusive Care for the Elderly (PACE) is excluded from the Inpatient Prospective Payment System for direct graduate medical and nursing and allied health education for Medicare Advantage enrollees. See the Medicare Claims Processing Manual, Chapter 3, section 20.8 for information on how to submit no-pay bills.

The PACE organization accepts the capitation payment amounts as payment in full. See PACE, Chapter 13 section 10.1.

Medicare & Veteran Affairs: Adjustments for Duplicate Claims Start Next Month
CMS entered into a computer matching agreement to identify claims paid by both Medicare and the Department of Veteran Affairs (VA). Starting next month, we’ll take action to recover any duplicate payments.

You must bill services authorized by the VA to the VA.

More Information

• Adjustment of Medicare Claims Where Veteran Affairs Also Made Payment MLN Matters article
• Medicare Secondary Payer Manual, Chapter 7, section 20.5.2

Hospital Price Transparency: Respond to Accuracy & Completeness RFI by July 21
Respond by 11:59 pm ET on July 21, 2025

CMS issued a Request for Information (RFI) seeking public input on whether and how we can improve hospital price transparency (HPT) compliance and enforcement processes to ensure that the hospital pricing data in the machine-readable file is accurate and complete. This RFI relates to the President’s Executive Order 14221 to ensure compliance with the transparent reporting of complete, accurate, and meaningful HPT data.

More Information:

• RFI 
• Press release 
• Updated guidance 

Join an Accountable Care Organization
Medicare providers: To participate in an Accountable Care Organization (ACO) for performance year 2026, work with an ACO to join their participant list. ACOs must submit their lists to CMS by August 1, 2025, by:

• Noon ET for the Medicare Shared Savings Program 
• 11:59 pm ET for the ACO REACH Model

Participant taxpayer identification numbers cannot overlap multiple ACO participant lists. Resolve any overlaps by September 8.

More Information

• Application Types & Timeline webpage
• Email questions to SharedSavingsProgram@cms.hhs.gov or ACOREACH@cms.hhs.gov

CMS Increasing Oversight on States Illegally Using Federal Medicaid Funding for Health Care for Illegal Immigrants
The Centers for Medicare & Medicaid Services (CMS) announced today increased federal oversight to stop states from misusing federal Medicaid dollars to cover health care for individuals who are in the country illegally. Under federal law, federal Medicaid funding is generally only available for emergency medical services for noncitizens with unsatisfactory immigration status who would otherwise be Medicaid-eligible, but some states have pushed the boundaries, putting taxpayers on the hook for benefits that are not allowed.

“Medicaid is not, and cannot be, a backdoor pathway to subsidize open borders,” said CMS Administrator Dr. Mehmet Oz. “States have a duty to uphold the law and protect taxpayer funds. We are putting them on notice—CMS will not allow federal dollars to be diverted to cover those who are not lawfully eligible.”

As part of the action, CMS is ramping up financial oversight across the board to identify and stop improper spending. This includes:

• Focused evaluations of select state Medicaid spending reports (CMS-64 form submissions)
• In-depth reviews of select states’ financial management systems
• Assessing existing eligibility rules and policies to close loopholes and strengthen enforcement

“Medicaid funds must serve American citizens in need and those legally entitled to benefits,” said CMS Deputy Administrator and Director of the Center for Medicaid & CHIP Services Drew Snyder. “If states cannot or will not comply, CMS will step in.”

CMS is also urging all states to immediately examine and update internal controls, eligibility systems, and cost allocation policies to ensure full compliance with federal law. Any improper spending on noncitizens will be subject to recoupment of the federal share.

This effort aligns with President Trump’s Executive Order on Ending Taxpayer Subsidization of Open Borders, reinforcing our commitment to restoring integrity to federal programs, securing the border, and putting Americans first. CMS will continue to act decisively to ensure Medicaid dollars serve their true purpose—protecting people eligible for the program under federal law. 

The letter to states is available at: https://www.cms.gov/files/document/open-borders-eo-notification-states.pdf 

CMS Releases Updated Telehealth and RPM MLN Booklet
In late April, the Centers for Medicare and Medicaid Services updated its Medicare Learning Network (MLN) Telehealth and Patient Monitoring Booklet to reflect recent policy changes made in compliance with H.R. 1968—the Continuing Resolution, which passed in March, and extends many Medicare telehealth flexibilities through September 30, 2025. CCHP covered these extensions in a previous newsletter, including highlighting the need for CMS to update their telehealth materials in light of the Medicare extensions.  Substantive updates in the updated booklet are marked in dark red for easy reference.  The updates include: 

• Audio-Only Telehealth: Continued allowance of audio-only communication for non-behavioral and non-mental health visits through September 30, 2025.
• Expanded Provider Eligibility: A broader range of Medicare-enrolled providers remain eligible to deliver telehealth services through September 30, 2025.
• Hospice Recertification: Providers may use telehealth to recertify hospice care eligibility through September 30, 2025.
• In-Person Visit Delays: Waived in-person visit requirements for behavioral and mental health services remain in place through September 30, 2025.
• FQHCs & RHCs: Federally Qualified Health Centers and Rural Health Clinics may continue delivering non-behavioral/mental telehealth services through September 30, 2025.  Note that CMS has also noted that FQHCs and RHCs can continue billing for non-behavioral health telehealth services using G2025 through Dec. 31, 2025, as reflected in the FQHC/RHC Chapter of the Medicare Benefit Policy Manual.
• Hospital at Home: The Acute Hospital Care at Home Program continues to operate under extended flexibilities through September 30, 2025.
• CPT code 98016:  This code, defined as a brief synchronous communication technology-based evaluation and management service, was removed from the booklet, with CMS stating that it qualifies as a Communication Technology-Based Service (CTBS), not a Medicare telehealth service.

Stakeholders are encouraged to review the updated MLN booklet to ensure alignment with current policy and billing requirements.  Note that the majority of the policies outlined above are currently set to expire on September 30, 2025, unless extended by future legislation or regulatory action. CCHP will continue to monitor developments and provide updates on post–September 30 telehealth and RPM policy changes in future newsletters.  See CCHP’s tracking of federal legislation to stay up to date on legislative developments.  

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