The coronavirus pandemic has shaken the healthcare industry and is placing caregivers and facilities under enormous clinical and financial strain. In an effort to lessen that strain and focus on patient health, the Centers for Medicare and Medicaid Services (CMS) has issued multiple directives to simplify administrative burdens and assist with reimbursement during this crisis. Since the situation is fluid, more government action may well be on the horizon. Meanwhile, these initial steps should be helpful. The current CMS COVID-19 changes include the following provisions:
CMS QPP Deadline Extended for COVID-19
In an effort to assist providers as they care for patients and staff during this time, CMS has extended the submission deadline for the 2019 Quality Payment Program (QPP) to April 30, 2020. MIPS & MIPS APM eligible clinicians now have until April 30, 2020 to attest and receive a potential positive payment adjustment. Clinicians who do not submit by the deadline will automatically be included in the extreme and uncontrollable circumstances policy and will have a neutral payment adjustment applied for the 2021 payment year.
Telemedicine Requirements for CMS COVID-19The recent Conronavirus Preparedness and Response Supplemental Appropriations Act of 2020 relaxed telehealth regulations, allowing CMS to more easily reimburse medical facilities for these services. Waiver 1135 expands Medicare's authority to pay for telehealth visits, including those held from an office, hospital, and other locations. Doctors, nurse practitioners, clinical psychologists, and other approved professionals will be able to perform these telehealth visits, often with patients who are in their own homes. This move allows vulnerable populations to isolate themselves from the virus while still receiving medical care.
Suspension of Non-Emergency InspectionsAlthough the CMS still expects compliance with its rule and regulations, it has suspended non-emergency inspections beginning March 4. This action allows inspectors to focus on virus containment and facilities to focus on patient care. However, CMS does recommend that all certified providers and suppliers monitor the COVID-19 CDC website and pertinent state websites for help with best practices and staying in compliance with the CMS rules.
Coronavirus TestingThose with Medicare Part B will have their coronavirus testing covered, often completely. This provision should reassure patients who need the test but fear the cost.
CMS COVID-19 Code ChangesCMS has created two new HCPCS codes for providers involved in coronavirus testing using the CDC 2019 Coronavirus Real-Time RT-PCR Diagnostic Test Panel and other approved tests. When billing for the CDC test, you should use code U0001. For non-CDC tests, code U0002 is appropriate.
Facility WaiversCMS response to the virus also includes waivers for facility treatment. For instance, skilled nursing facilities (SNF) can admit patients without the usual three-day prior hospitalization requirement. Also, those patients who have already exhausted their SNF benefits can have them renewed before a new benefit period arrives. CMS is also temporarily allowing critical access hospitals to have more than 25 beds and permit stays that go longer than the usual 96 hours. Acute care patients can now be placed in previously excluded district part units as long as the unit has the necessary equipment for treatment. Durable medical equipment (DME) regulations have also been eased to allow contractors to replace equipment without the usual face-to-face requirement, new physician's order, and new documentation. Provider location requirements have been changed so that providers can practice out-of-state without being licensed in that state. Other changes affect home health agencies, supporting care for patients in long-term care, and acute care hospitals.
Provider Enrollment FlexibilityProviders' enrollment regulations have also been temporarily eased, with requirements for an application fee, criminal background check, and site visits being waived. In addition, all revalidation actions have been postponed. CMS is working to expedite any new or pending provider applications as well. The goal is to mitigate any provider shortage that may occur.
CMS Appeal RevisionsCMS is granting extensions to file an appeal in Fee for Service, Medicare Advantage, and Part D. The timeliness requirement for more information to adjudicate the appeal has also been waived. Appeal requests that lack certain data will still be processed by using the information that was provided. In general, CMS will be as flexible as possible in this area to expedite the appeal process while facilities are dealing with a massive influx of patients.
CHIP and Medicaid WaiversThe President's emergency declaration means that certain waivers must be put into effect. These waivers affect some Medicare, Medicaid and Children's Health Insurance Program (CHIP) authorities and fall under Section 1135 of the Social Security Act. Although there is no particular form for the request of such a waiver, each state or territory should provide the government with all pertinent information in order to expedite their requests.
CMS ToolkitA CMS COVID-19 toolkit for providers to help you better address this crisis while remaining safe. The online kit contains links to helpful videos, CMS websites and articles, FDA and CDC links, provider-specific help, and other tools to keep you up-to-date on virus prevention and treatment. The scope of this pandemic changes daily, with New York currently serving as the country's, and perhaps the world's, new epicenter. Health officials warn that the country has not neared the peak of its infection curve. As a result, you can expect further measures and guidance from the CMS as the crisis progresses.
The TempDev AdvantageTempDev's team of expert consultants stands ready to assist you in any way possible. They offer the latest in NextGen solutions, which can help you manage cases in your facility as well as accurately bill for them. At this time, your staff is in danger of being overwhelmed by the sheer number of concerned patients, many who wish to be tested for the virus. Partnering together on creating innovative solutions to fight the pandemic can help both your patients and staff by allowing them to function more efficiently and spend more time on patient treatment during this difficult time. CMS has taken some concrete steps to address the virus and simplify testing, claim submission, quality submission, and reimbursement. Continue to look for updates from us about ways to mitigate your risk as the pandemic continues.
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