On May 27, 2020, CMS issued updated FAQs. Among other topics, CMS noted that the RHC productivity limits may be waived during the COVID period at the discretion of the MACs (page 31). Based on this FAQ, if an RHC expects to have difficulty meeting the productivity guideline because of COVID, they should proactively consult with their MAC.
Another FAQ notes the treatment of telehealth costs on the cost reports (page 32). This FAQ response is consistent with current cost reporting instructions – as non-reimbursable costs excluded from the all-inclusive rate calculation. Other RHC FAQs are on pages 31-33.
The FAQs are attached and available at the following link.
The FAQs in this document supplement the previously released FAQs: 1135 Waiver FAQs, available at https://www.cms.gov/About-CMS/Agency-Information/Emergency/Downloads/MedicareFFS-EmergencyQsAs1135Waiver.pdf.