Dr. Rachel Levine, under her authority as Secretary of the Department of Health to take any disease control measure appropriate to protect the public from the spread of infectious disease, signed an order directing protections for critical workers who are employed at businesses that are authorized to maintain in-person operations during the COVID-19 disaster emergency.

The entire press release can be found here.

 

On April 17, 2020, Pennsylvania Governor Tom Wolf announced a Plan for Pennsylvania that will provide citizens and businesses relief, allow for a safe and expedient reopening, and lay a road to recovery from the challenges and hardships created by the 2019 novel coronavirus.

The proposal includes plans for food insecurity, student loan debt, individuals who have been furloughed, laid off, or have reduced hours, individuals who are uninsured or underinsured, students and families, relief for businesses, and standards for reopening.

MLN Matters Number: SE20016

Article Release Date: April 17, 2020

Related CR Transmittal Number: N/A

Related Change Request (CR) Number: N/A

Effective Date: N/A

Implementation Date: N/A

PROVIDER TYPES AFFECTED

This MLN Matters® Special Edition Article is for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) during the COVID-19 Public Health Emergency (PHE) for services provided to Medicare beneficiaries.

WHAT YOU NEED TO KNOW

To provide as much support as possible to RHCs and FQHCs and their patients during the COVID-19 PHE, both Congress and the Centers for Medicare & Medicaid Services (CMS) have made several changes to the RHC and FQHC requirements and payments. These changes are for the duration of the COVID-19 PHE, and we will make additional discretionary changes as necessary to assure that RHC and FQHC patients have access to the services they need during the pandemic. For additional information, please see the RHC/FQHC COVID-19 FAQs at https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf.

BACKGROUND

New Payment for Telehealth Services

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law. Section 3704 of the CARES Act authorizes RHCs and FQHCs to furnish distant site telehealth services to Medicare beneficiaries during the COVID-19 PHE. Medicare telehealth services generally require an interactive audio and video telecommunications system that permits real-time communication between the practitioner and the patient. RHCs and FQHCs with this capability can immediately provide and be paid for telehealth services to patients covered by Medicare for the duration of the COVID-19 PHE.

Distant site telehealth services can be furnished by any health care practitioner working for the RHC or the FQHC within their scope of practice. Practitioners can furnish distant site telehealth services from any location, including their home, during the time that they are working for the RHC or FQHC, and can furnish any telehealth service that is approved as a distant site telehealth service under the Physician Fee Schedule (PFS). A list of these is available at https://www.cms.gov/files/zip/covid-19-telehealth-services-phe.zip.

The statutory language authorizing RHCs and FQHCs as distant site telehealth providers requires that CMS develop payment rates for these services that are similar to the national average payment rates for comparable telehealth services under the PFS. Payment to RHCs and FQHCs for distant site telehealth services is set at $92, which is the average amount for all PFS telehealth services on the telehealth list, weighted by volume for those services reported under the PFS.

For telehealth distant site services furnished between January 27, 2020, and June 30, 2020, RHCs and FQHCs must put Modifier “95” (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) on the claim. RHCs will be paid at their all-inclusive rate (AIR), and FQHCs will be paid based on the FQHC Prospective Payment System (PPS) rate. These claims will be automatically reprocessed in July when the Medicare claims processing system is updated with the new payment rate. RHCs and FQHCs do not need to resubmit these claims for the payment adjustment.

For telehealth distant site services furnished between July 1, 2020, and the end of the COVID-19 PHE, RHCs and FQHCs will use an RHC/FQHC specific G code, G2025, to identify services that were furnished via telehealth. RHC and FQHC claims with the new G code will be paid at the $92 rate. Only distant site telehealth services furnished during the COVID-19 PHE are authorized for payment to RHCs and FQHCs. If the COVID-PHE is in effect after December 31, 2020, this rate will be updated based on the 2021 PFS average payment rate for these services, weighted by volume for those services reported under the PFS.

Costs for furnishing distant site telehealth services will not be used to determine the RHC AIR or the FQHC PPS rates but must be reported on the appropriate cost report form. RHCs must report both originating and distant site telehealth costs on Form CMS-222-17 on line 79 of the Worksheet A, in the section titled “Cost Other Than RHC Services.” FQHCs must report both originating and distant site telehealth costs on Form CMS-224-14, the Federally Qualified Health Center Cost Report, on line 66 of the Worksheet A, in the section titled “Other FQHC Services”.

Since telehealth distant site services are not paid under the RHC AIR or the FQHC PPS, the Medicare Advantage wrap-around payment does not apply to these services. Wrap-around payment for distant site telehealth services will be adjusted by the MA plans.

During the COVID-19 PHE, CMS will pay all of the reasonable costs for any service related to COVID-19 testing, including applicable telehealth services, for services furnished beginning on March 1, 2020. For services related to COVID-19 testing, including telehealth, RHCs and FQHCs must waive the collection of co-insurance from beneficiaries. For services in which the coinsurance is waived, RHCs and FQHCs must put the “CS” modifier on the service line.

RHC and FQHC claims with the “CS” modifier will be paid with the coinsurance applied, and the Medicare Administrative Contractor (MAC) will automatically reprocess these claims beginning on July 1. Coinsurance should not be collected from beneficiaries if the coinsurance is waived.

Expansion of Virtual Communication Services

Payment for virtual communication services now include online digital evaluation and management services. Online digital evaluation and management services are non-face-to-face,

patient-initiated, digital communications using a secure patient portal. The online digital evaluation and management codes that are billable during the COVID-19 PHE are:

• CPT code 99421 (5-10 minutes over a 7-day period)
• CPT code 99422 (11-20 minutes over a 7-day period)
• CPT code 99423 (21 minutes or more over a 7-day period)

To receive payment for the new online digital evaluation and management (CPT codes 99421, 99433, and 99423) or virtual communication services (HCPCS codes G2012 and G2010), RHCs and FQHCs must submit an RHC or FQHC claim with HCPCS code G0071 (Virtual Communication Services) either alone or with other payable services. For claims submitted with HCPCS code G0071 on or after March 1, 2020, and for the duration of the COVID-19 PHE, payment for HCPCS code G0071 is set at the average of the national non-facility PFS payment rates for these 5 codes. Claims submitted with G0071 on or after March 1 and for the duration of the PHE will be paid at the new rate of $24.76, instead of the CY 2020 rate of $13.53.

MACs will automatically reprocess any claims with G0071 for services furnished on or after March 1 that were paid before the claims processing system was updated.

Revision of Home Health Agency Shortage Requirement for Visiting Nursing Services

RHCs and FQHCs can bill for visiting nursing services furnished by an RN or LPN to homebound individuals under a written plan of treatment in areas with a shortage of home health agencies (HHAs). Effective March 1, 2020, and for the duration of the COVID-19 PHE, the area typically served by the RHC, and the area included in the FQHC service area plan, is determined to have a shortage of HHAs, and no request for this determination is required. RHCs and FQHCs must check the HIPAA Eligibility Transaction System (HETS) before providing visiting nurse services to ensure that the patient is not already under a home health plan of care.

Consent for Care Management and Virtual Communication Services

Beneficiary consent is required for all services, including non-face-to-face services. During the PHE, beneficiary consent may be obtained at the same time the services are initially furnished. For RHCs and FQHCs, this means that beneficiary consent can be obtained by someone working under general supervision of the RHC or FQHC practitioner, and direct supervision is not required to obtain consent. In general, beneficiary consent to receive these services may be obtained by auxiliary personnel under general supervision of the billing practitioner; and the person obtaining consent can be an employee, independent contractor, or leased employee of the billing practitioner. For RHCs and FQHCs, beneficiary consent to receive these services may be obtained by auxiliary personnel under general supervision of the RHC or FQHC practitioner; and the person obtaining consent can be an employee, independent contractor, or leased employee of the RHC or FQHC practitioner (see: https://www.cms.gov/files/document/covid-final-ifc.pdf).

 Accelerated/Advance Payments

In order to increase cash flow to providers and suppliers impacted by COVID-19, CMS has expanded our current Accelerated and Advance Payment Program. An accelerated/advance payment is a payment intended to provide necessary funds when there is a disruption in claims

 20016Related CRN/A submission and/or claimsprocessing. CMS is authorized to provide accelerated or advancepayments during the period of the PHE to any RHC orFQHC who submitsa requestto theirMACand meets the required qualifications.Each MACwillwork to review requestsand issuepayments within seven calendar days of receiving the request. Traditionallyrepayment ofthese advance/accelerated payments begins at 90 days; however,forthe purposes of the COVID-19 pandemic, CMS has extended the repayment ofthese accelerated/advance payments to begin 120 days after the date of issuance of the payment. Providers can get more information on thisprocessathttps://www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf.

ADDITIONALINFORMATION

View the complete list of coronaviruswaivers.

Review information on the current emergencies webpage athttps://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/Current-Emergencies-page.If you have questions, your MACs may have more information. Find their website at http://go.cms.gov/MAC-website-list.

With COVID-19 turning home into the workplace nationwide, the personal-finance website WalletHub today released its report on the Best States for Working from Home, as well as accompanying videos, in order to highlight which areas are thriving and which are struggling in this pandemic economy.

To identify which states are most conducive to working from home, WalletHub compared the 50 states and the District of Columbia across 12 key metrics. The data set ranges from the share of workers working from home before COVID-19 to internet cost and cybersecurity. We also considered factors like how large and how crowded homes are in the state. Together, these metrics show how feasible working from home is in terms of cost, comfort and safety. Below, you can see highlights from the report, along with a WalletHub Q&A.

Best States for Working from Home	Worst States for Working from Home
1. Delaware	42. District of Columbia
2. Washington	43. Wyoming
3. New Hampshire	44. Iowa
4. Colorado	45. Rhode Island
5. Georgia	46. North Dakota
6. Arizona	47. Oklahoma
7. Utah	48. Arkansas
8. Oregon	49. Mississippi
9. North Carolina	50. Hawaii
10. South Dakota	51. Alaska

Key Stats

• Colorado has the highest share of the labor force working from home, 7.70 percent, which is 3.3 times higher than in Mississippi, the state with the lowest at 2.30 percent.
• New Hampshire has the highest share of households with a broadband internet subscription, 78.80 percent, which is 1.7 times higher than in Mississippi, the state with the lowest at 46.80 percent.
• Connecticut has the highest share of households with access to broadband speeds over 25 Mbps, 98.70 percent, which is 1.5 times higher than in Mississippi, the state with the lowest at 65.40 percent.
• South Dakota has the fewest cybercrime victims per 100,000 residents, 54.73, which is four times fewer than in Nevada, the state with the most at 218.31.
• Indiana has the lowest amount lost per victim as a result of internet crime, $2,465.73, which is 11.5 times lower than in Ohio, the state with the highest at $28,394.32.
• North Dakota has the lowest residential retail price of electricity, 9.01 cents per kWh, which is 3.5 times lower than in Hawaii, the state with the highest at 31.70 cents per kWh.

To view the full report and your state’s rank, please visit:
https://wallethub.com/edu/best-states-for-working-from-home/72801/

The Pennsylvania Department of Community and Economic Development (DCED) Secretary Dennis Davin announced the creation of the Business-to-Business Interchange Directory to connect organizations and businesses directly to manufacturers producing COVID-19-related products and supplies.

Company and product information provided in the directory were gathered in good faith as a means of connecting Pennsylvania businesses and organizations that are seeking various PPE and other related items to combat the COVID-19 crisis. The information made available is from those entities who voluntarily contacted the commonwealth through the Manufacturing Call to Action Portal or the Pennsylvania Critical Medical Supplies Procurement Portal.

Currently included in the directory are manufacturers of N95 masks, fabric and other masks, and surgical masks. Additional supplies and materials will be added to the directory as DCED identifies potential manufacturers. Businesses that would like to be added to the directory or those with questions should contact RA-DCEDPAMCTAP@pa.gov.

The Pennsylvania Department of Community and Economic Development (DCED) Secretary Dennis Davin announced that 126 companies in 30 counties have received approved funding through a new program developed under the Pennsylvania Industrial Development Authority’s (PIDA) Small Business First Fund, the COVID-19 Working Capital Access Program (CWCA), totaling more than $10 million.

A list of approved projects can be found here.

PIDA staff continue to review submitted applications for approval and are actively working with DCED’s Certified Economic Development Organizations (CEDOs) to disburse CWCA loan funds at the time of approval. Information on future awardees will be released as it becomes available. 

DCED continues to update its website with financial and other resources. 

Today, the Centers for Medicare & Medicaid Services issues new recommendations specifically targeted to communities that are in Phase 1 of the Guidelines for President Trump’s Opening Up America Again with low incidence or relatively low and stable incidence of COVID-19 cases. The recommendations update earlier guidance provided by CMS on limiting non-essential surgeries and medical procedures. The new CMS guidelines recommend a gradual transition and encourage health care providers to coordinate with local and state public health officials, and to review the availability of personal protective equipment (PPE) and other supplies, workforce availability, facility readiness, and testing capacity when making the decision to re-start or increase in-person care.

The new recommendations can be found here: https://www.cms.gov/files/document/covid-flexibility-reopen-essential-non-covid-services.pdf

The Guidelines for Opening Up America Again can be found here: https://www.whitehouse.gov/openingamerica/#criteria

Agencies partner with nursing homes to keep nursing home residents safe

Today, under the leadership of President Trump, the Centers for Medicare & Medicaid Services (CMS) announced new regulatory requirements that will require nursing homes to inform residents, their families and representatives of COVID-19 cases in their facilities. In addition, as part of President Trump’s Opening Up America, CMS will now require nursing homes to report cases of COVID-19 directly to the Centers for Disease Control and Prevention (CDC). This information must be reported in accordance with existing privacy regulations and statute. This measure augments longstanding requirements for reporting infectious disease to State and local health departments. Finally, CMS will also require nursing homes to fully cooperate with CDC surveillance efforts around COVID-19 spread.

CDC will be providing a reporting tool to nursing homes that will support Federal efforts to collect nationwide data to assist in COVID-19 surveillance and response. This joint effort is a result of the CMS-CDC Work Group on Nursing Home Safety. CMS plans to make the data publicly available. This effort builds on recent recommendations from the American Health Care Association and Leading Age, two large nursing home industry associations, that nursing homes quickly report COVID-19 cases.

This data sharing project is only the most recent in the Trump Administration’s rapid and aggressive response to the COVID-19 pandemic. More details are available in the Press Release and Guidance Memo.

Mathematica continues to partner with our clients and groups like the National Association of Health Data Organizations (NAHDO) to respond to the evolving COVID-19 pandemic, particularly in the area of data analytics. COVID-19 has affected health care administrative data, such as claims, in several ways. Notably, it has led to changes in diagnostic and procedural coding guidelines, payment policies, and shifts in case mix. Analysts, actuaries, and data scientists need this information to respond to these changes, but the information is scattered across many sources focused on specific topics (such as coding telehealth services in Medicaid claims).

In response, Mathematica created a COVID-19 Data Primer.  Read more here.