Program updates: COVID-19

PIP/CPC+ incentive programs and Risk Adjustment program 

We're monitoring COVID-19 and its potential impacts to our risk-based contracts, incentive programs and Risk Adjustment programs.

As we assess these programs and monitor local and national trends, including HEDIS and NCQA, we'll continue to partner with you and keep you informed as we learn more and develop solutions. Continue to reference this page for the most up-to-date information regarding the impact of COVID-19 on our incentive programs. 

2019/2020 program deadlines

In response to COVID-19, we've adjusted the following program deadlines for our 2020 program year. 

PCP Incentive Program (PIP) and Comprehensive Primary Care Plus (CPC+) deadlines

Submission Original deadline New deadline
PIP 2019 MTM attestation deadline 3/13/2020 3/25/2020
PIP 2019 Comprehensive Primary Care Plus (CPC+) recoupment payback 7/3/2020 8/31/2020
PIP 2020 Risk Adjustment Measure attestation 3/13/2020 5/1/2020
PIP 2020 Care Management attestation survey (final deadline) 5/29/2020 5/29/2020
PIP 2020 MiHIN submission on use case adoption 10/1/2020 Under review
PIP 2020 Medicaid Patient Centered Medical Home (PCMH) recognition and MiHIN use case attestation survey 10/30/2020 11/30/2020
PIP 2020 Member discharge/transfers 10/31/2020 10/31/2020
PIP 2020 Non-adherent member exclusion requests  11/6/2020 12/4/2020
PIP 2020 Supplemental data audit (pass/fail) 12/28/2020 12/28/2020
PIP 2020 CG CAHPS data submission 1/31/2021 Under review
PIP 2020 Member special exceptions: Active Duty, LTC, Deceased 1/31/2021 1/31/2021
PIP 2020 Supplemental data submission 1/31/2021 Under review
PIP 2020 Final claims submission 2/28/2021 2/28/2021
PIP 2020 MDHHS PCMH designation status  August 2021 Under review

Risk Adjustment deadlines

Submission Original deadline New deadline
2019 ACA Risk Adjustment and Advanced Health Assessment (AHA) chart retrieval deadline 4/15/2020 4/15/2020*
2020 ACA Risk Adjustment and AHA chart retrieval deadline 3/30/2021 3/30/2021*
ACA Risk Adjustment Data Validation (RADV) audit July 2020 July 2020
2019 Medicare Risk Adjustment retro chart retrieval deadline 10/31/2020 Under review - pending CMS
AHA chart retrieval - MA (CY 2019) 3/6/2020 3/6/2020
AHA chart retrieval - MA (CY 2020) 3/5/2021 3/5/2021
Medicare RADV audit 7/10/2020 Under review
HEDIS chart retrieval (all lines of business) 5/7/2020 Under review - pending NCQA

*Subject to change based on health plan and CMS guidance

Advanced Health Assessment (AHA program)

In response to the COVID-19 pandemic, the Centers for Medicare and Medicaid Services (CMS) has issued guidance that telehealth visits (real-time video with audio) are acceptable as risk adjustment encounters, as long as the visit meets the criteria for risk adjustment eligibility.

This means that practices participating in the AHA program can see patients via a virtual visit and it will qualify as an AHA encounter. We'll also pay AHA incentives for AHA-targeted members for AHA visits done via a virtual visit. This information applies to both Medicare and Patient Protection and Affordable Care Act (PPACA) plans.

As a reminder, risk adjustment criteria include a face-to-face visit with an appropriate provider (physician or advanced practice provider). Therefore, AHAs must be completed using a telehealth service that includes video with audio.  

Billing for an AHA visit done through telehealth

  • You should bill for an AHA visit done through telehealth by using one of the approved CPT codes for an AHA visit (see chart below).
  • Starting May 1, 2020, bill using the place of service you'd normally use for the in-person visit. Add the modifier 95 to identify the visit as telehealth.
  • As a reminder, you must indicate the completion of an AHA visit by billing S0250 HCPCS code (at no charge on the claim), along with the applicable evaluation and management (E/M) code.

AHA-approved codes for MAPD and PPACA

Codes listed below are based on current information from CMS. This list will be updated as more information becomes available. Although visits are being done via telehealth, the visit must still follow the guidelines of each CPT code, including time requirements. 

Approved CPT codes for AHA visit (Telehealth)
99203 99213 99495*
99204 99214 99496*
99205 99215 G0438*

*Approved for MAPD only. Not for use with PPACA

AHA re-billing

In response to the COVID-19 pandemic, we are allowing practices to re-bill Advanced Health Assessments (AHAs) done via telehealth retrospectively back to 4/1/2020. This applies for both Medicare and PPACA.

If the practice has already billed a claim, they will need to re-bill as a corrected claim to avoid duplicate rejections, just as they would with a face-to-face AHA visit. For instructions on billing for AHA visits done via telehealth, including approved codes, reference the "Billing for an AHA visit done through telehealth" section of this page, above.

If a practice decides to re-bill, the telehealth re-bill must meet AHA requirements to capture the patient's full burden of illness.

Frequently asked questions: program updates

Can I conduct a Health Risk Assessment (HRA) for Healthy Michigan Plan members virtually? Will it count toward the PCP Incentive Program (PIP) HRA measure? 

Yes, you can conduct HRAs virtually and receive PIP measure credit. HRA forms can by submitted via the Community Health Automated Medicaid Processing System (CHAMPS) or faxed to Priority Health at 616.942.0616.

For more information about HRA form submission and the PIP incentive, visit the Healthy Michigan Plan HRA provider manual page.

For more information about virtual visits and telehealth, see our COVID-19: Virtual visits and telehealth page

Will Priority Health provide advanced payments for our 2019 PCP Incentive Program (PIP) settlement? 

No. We are on track to deliver on-time payments on Apr. 15, 2020 for our 2019 program year.