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COVID-19 – Healthcare Service Providers Updates and Implications

Tiffany Karlin

March 20, 2020

AHCA Guidance

LeadingAge Guidance

NAHC Guidance

AHCA Screening Visitors Checklist for Operations with Elderly and Vulnerable Patients

  1. Will there be any form of reimbursement for COVID costs?
    • Fortunately, last week, the House passed legislation that increases the federal Medicaid match (FMAP) by 6.2%.
  2. Will the three day hospital stay remain in effect? 
    • Based upon the President’s actions and the Secretary’s authority under Section 1135 and Section 1812(f), SNF care without a 3-day inpatient hospital stay will be covered for beneficiaries who experience dislocations or are affected by the emergency.
    • Get the Facts from AHCA
    • Bill for it:
  1. Has cost report deadline for Medicare been extended?
  2. What Telehealth services can be billed from a Skilled Nursing Facility (SNF)?
    • CMS is expanding Medicare’s telehealth benefits under the 1135 waiver authority and the Coronavirus Preparedness and Response Supplemental Appropriations Act. Under this new waiver, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country and including in patient’s places of residence starting March 6, 2020.  A range of providers, such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, will be able to offer telehealth to their patients.  Additionally, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.
  3. How do I bill for telehealth?
    • At this time, we believe the only Telehealth code that can be billed from the SNF is Q3014 (Originating Site Facility Fee)
    • All SNF’s must use revenue code 078X when billing for the originating site facility fee. The SNF serving as an originating site must bill for HCPCS code Q3014 on a separate revenue line from any other services provided to the beneficiary.
  4. Telehealth and Home Health and Hospice:
    • Home Health Agencies can provide more services to beneficiaries using telehealth within the 30 day episode of care, so long as it’s part of the patient’s plan of care and does not replace needed in-person visits as ordered on the plan of care.
    • Hospice providers can provide services to a Medicare patient receiving routine home care through telehealth, if it is feasible and appropriate to do so. Face-to-face encounters for purposes of patient recertification for the Medicare hospice benefit can now be conducted via telehealth.
    • CMS Telehealth FAQs

CMS Fact Sheet

CMS Released Guidance for Waivers and Flexibilities due to COVID-19:

CMS for Long Term Care Facilities
CMS for Home Health Agencies
CMS for Hospice Agencies
CMS for Rural Health Clinics

  1. Can visitors come into my healthcare center?
    • In the new guidance, CMS directs ALL Facilities nationwide to restrict visitation of all visitors and non-essential health care personnel, except for certain compassionate care situations, such as an end-of-life situation
  1. Can Surveyors/Auditors enter our building?
    • CMS is only suspending certain non-emergency state survey inspections, allowing inspectors to prioritize the most serious health and safety threats like infectious diseases and abuse.
    • CMS: Suspension of Survey Activities
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