CMS recently updated recommendations to postpone non-essential surgeries and other procedures to conserve critical healthcare resources and limit exposure of patients and staff to COVID-19. Developed in collaboration with medical societies and associations, the recommendations outline a tiered approach for state and local officials, clinicians, and delivery systems to consider to prioritize services and care to those who require emergent or urgent attention to save a life, manage severe disease, or avoid further harms from an underlying condition.

Recommendations

CMS posted a letter to clinicians that outlines a summary of actions CMS has taken to ensure clinicians have maximum flexibility to reduce unnecessary barriers to providing patient care during the unprecedented outbreak of COVID-19. The summary includes information about telehealth and virtual visits, accelerated and advanced payments, and recent waiver information.

Letter

• The CARES Act included Medicare telehealth flexibility for FQHCs and RHCs for the duration of the crisis. It authorizes Medicare reimbursement for health centers and rural health clinics as distant sites for the duration of the emergency, not reimbursed at PPS rate but instead “such payment methods shall be based on payment rates that are similar to the national average payment rates for comparable telehealth services under the physician fee schedule under section 1848.”
• Since 2019, FQHCs could bill Medicare for virtual communication services (aka phone calls) using code GOO71. (This is in lieu of the codes 99441, 99442, and 99443, which only those providers who bill under the fee schedule can use.) The payment is around $14, and FQHCs cannot bill for it if the patient had a related evaluation/management service within the previous 7 days or has an on-site appointment within the next 24 hours. These services must be initiated by a patient and as long as the provider responding to the call is an employee or contractor of the health center, he or she does not have to be physically located at the health center while delivering these services. CMS also has an FAQ document on virtual communication.

On March 30 the Centers for Medicare & Medicaid Services (CMS) issued an array of new rules and waivers of federal requirements offering maximum flexibility to respond to the COVID-19 pandemic including a section entitled “Further Promote Telehealth in Medicare.” There is a provider-specific fact sheet on new waivers and flexibilities for FQHCs and RHCs but it does not address telehealth.

The Small Business Administration (SBA) released the loan application for the Paycheck Protection Program and an information sheet containing loan guidelines. Some highlights of the guidelines:

• April 3, 2020: Loan applications will start being accepted for businesses and sole proprietors
• April 10, 2020: Loan applications will start being accepted for independent contractors and self-employed individuals
• More lenders will be added as they are approved/enrolled. To apply, you should reach out to one of the approved lenders
• There are no changes to affiliation standards from those specified in the CARES Act. However, additional guidance may be released by SBA as appropriate
• All loan terms will be the same for everyone
• Due to anticipated high demand, SBA anticipates allowing not more than 25% of the forgiven loan amount to be used for nonpayroll costs (utilities, rent and interest on a mortgage)
• Interest Rate: 1% fixed rate, lowered from 4%
• Maturity: 2 years, shortened from 10 years

Since the beginning of this pandemic, there has been a push to establish a Health Insurance Marketplace Special Enrollment Period (SEP) due to the COVID-19 Emergency Declaration. The Trump administration has decided against reopening the Marketplace to those needing coverage during the coronavirus pandemic. The Special Enrollment Period (SEP) for loss of coverage is still available for individuals losing job-based coverage. Consumers have 60 days from the last day of coverage to sign up for an SEP. In Pennsylvania, Medicaid benefits will not be terminated for consumers as of March 18 until the end of the emergency declarations unless the individual leaves the state or voluntarily terminate their benefits. While county assistance offices remain closed to the public, consumers can still apply online and via the mobile app. Documents needed for verification can be submitted via the COMPASS webpage, mobile app or dropped off at county assistance office locations in the designated mailbox.

We know that the need and demand for personal protective equipment (PPE) continues to far exceed supply.  There are many others who are also aware of that fact and some of them are preying on the desperation for supplies, exhaustion from juggling so many priorities in responding to the COVID-19 pandemic, and strong desire to protect our workers on the front line.  Because there are many unscrupulous players in the market right now, PACHC urges caution in these desperate times when accepting offers.  Here are some initial checks to evaluate offers:

• Large Minimum Order Quantities?  Any provider that is established in this space would be stocking and able to ship case pack quantities. Legitimate providers would not be putting large Minimum Order Quantities (MOQs) out.
• Suspicious Pricing?  Legitimate providers aren’t pricing products significantly above what you could search an item for on the internet or a previous price paid.
• Do They Have a Website?  Not a foolproof check by any means because it’s easy to set up fake sites these days, but an easy rule-out if they don’t have one.
• Do They Have the Appropriate Certifications?  NIOSH, CDC or other?

Can They Send You a Product Sample and/or Product Specification Sheet?  If a distributor is able to do so you have another level of assurance that you are more likely to get what you’re paying for.

The Institute of State and Regional Affairs at Penn State Harrisburg has released a report to help guide strategic planning in response to the COVID-19 outbreak in Pennsylvania. The report compares counties in Pennsylvania based on medical risk factors relating to COVID-19. The institute found that the three Pennsylvania counties with the highest relative risk, Sullivan, Northumberland and Juniata, are not yet showing high rates of infection.

“Efforts to mitigate the spread of COVID-19 in Pennsylvania have been strong and grounded in the best available evidence. This analysis provides new information that may aid strategic efforts to promote the health and safety of communities at greatest risk,” said Institute Director Philip Sirinides.

Rather than mapping current hot spots of COVID-19, this report’s purpose is to highlight areas where the outcomes from COVID-19 may be more severe. To highlight which Pennsylvania counties have the most vulnerable populations, the institute collected data relating to age, prevalence of cardiovascular disease and diabetes, available hospital staff and beds, and nursing home populations, all factors associated with COVID-19 risk identified by the Centers for Disease Control and Prevention.

Click here to read the report on medical risk and COVID-19 in Pennsylvania. 

During the COVID-19 Public Health Emergency, Medicare will cover a medically necessary emergency and non-emergency ground ambulance transportation from any point of origin to a destination that is equipped to treat the condition of the patient consistent with state and local Emergency Medical Services (EMS) protocols where the services will be furnished. On an interim basis, we are expanding the list of destinations that may include but are not limited to:

• Any location that is an alternative site determined to be part of a hospital, Critical Access Hospital (CAH), or Skilled Nursing Facility (SNF)
• Community mental health centers
• Federally Qualified Health Centers (FQHCs)
• Rural health clinics (RHCs)
• Physicians’ offices
• Urgent care facilities
• Ambulatory Surgery Centers (ASCs)
• Any location furnishing dialysis services outside of an End-Stage Renal Disease (ESRD) facility when an ESRD facility is not available
• Beneficiary’s home

CMS expanded the descriptions for these origin and destination claim modifiers to account for the new covered locations:

• Modifier D – Community mental health center, FQHC, RHC, urgent care facility, non-provider-based ASC or freestanding emergency center, location furnishing dialysis services and not affiliated with ESRD facility
• Modifier E – Residential, domiciliary, custodial facility (other than 1819 facility) if the facility is the beneficiary’s home
• Modifier H – Alternative care site for hospital, including CAH, provider-based ASC, or freestanding emergency center
• Modifier N – Alternative care site for SNF
• Modifier P – Physician’s office
• Modifier R – Beneficiary’s home

For the complete list of ambulance origin and destination claim modifiers see Medicare Claims Processing Manual Chapter 15, Section 30 A.