By Bonnie Kirschenbaum, MS, FASHP, FCSHP

In unprecedented crisis of COVID-19, the first instinct is to triage our activities, often weeding out the ones that seem to be the least important. Some of those will never surface again and just become part of the detritus left behind. 

However, documentation mustn’t be one of them. From a clinical standpoint, documentation is critical to caring for patients with COVID-19; it’s essential to tell the patient’s story accurately and completely. When this is done in a codable manner, it’s the key to bringing in desperately needed income and decreasing financial toxicity for the patient who’s often eligible for expanded resources. Such efforts also will help avoid medical billing and payment issues in the months and years following this pandemic.

Tucked into the recent CARES Act, the Coronavirus Preparedness and Response Supplemental Appropriations Act (also known as the stimulus package), is a provision that temporarily removes the Medicare sequester from May 1 through Dec. 31, 2020, and extends it an additional year past its original end date. This provides you with a guaranteed 2% increase on all Medicare payments. The caveat: The claim needs to be clean and complete with no inaccuracies, errors or missing information to be processed quickly and paid completely.

I’m urging you to find someone within your department who can shoulder the responsibility of making this happen. Perhaps it’s someone, even working from a remote location, who can’t have front-line responsibilities but who will be the steady driving force for financial solvency. The stimulus package is providing the funding, but it’s up to each one of you to ask for it and use it wisely to help cover COVID-19-related expenses and lost revenue.

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The supplement also provides a 20% add-on payment to the DRG  rate for COVID-19. This Medicare add-on payment applies to patients treated at hospitals that are reimbursed through IPPS with a new ICD-10-CM diagnosis code, U07.1. An enhanced grouper assignment effective for discharges on or after April 1, 2020, corrects the underpayments possible from the original grouper assignment.

Other key features include: 

  • eliminating $8 billion in Medicaid disproportionate share hospital payment cuts in FY2020, FY2021 (a $4 billion reduction with implementation of cuts is delayed until Dec. 1, 2020); 
  • extending Medicare and Medicaid programs set to expire on May 22 until Nov. 30, setting up a potential vehicle for legislation to ban surprise medical bills and address prescription drug prices after the 2020 election;
  • mandating more reporting requirements about where pharmaceutical companies source their materials and allowing the FDA to prioritize drug applications that could help address a shortage; and 
  • covering vaccines that meet certain effectiveness standards with no cost sharing.

Telehealth Shines!

Implementing and expanding telehealth services helps fill the COVID-19 screening and treatment gap and also helps prevent the spread of the infection. In addition to several initiatives, HHS will waive federal licensing regulations so out-of-state physicians can treat patients through telehealth in states that have large outbreaks.

The HHS secretary was charged with developing and implementing a new payment rule for federally qualified health centers and rural health clinics that provide telehealth services to eligible patients. Payment rates would be based on the payment that currently applies to comparable telehealth services under the PFS. In addition, HHS is to issue guidance on using telehealth for home health services. This allows Medicare beneficiaries to use telehealth services regardless of whether they had seen the provider in person in the preceding three years.

Put These Into Your e-Library!

On March 20, CMS released two digital telehealth tool kits, one specific to general practitioners and the other for providers treating patients with end-stage renal disease.

“Each toolkit comprises electronic links to telehealth resources to reduce the amount of time providers spend looking for answers on new regulations,” the agency stated. “The toolkits is structured to help you learn more about the general concept of virtual care, choose telehealth vendors, initiate a program and develop documentation tools. The toolkits also offer outlines of temporary telehealth services that could be implemented to treat patients during the COVID-19 pandemic.”

According to CMS's March 17 fact sheet, clinicians could bill immediately for dates of service starting March 6, 2020. Telehealth services are paid under the PFS at the same amount as in-person services. HHS also is waiving certain Medicare telehealth payment requirements to enable telehealth services to be provided in all settings, including a patient's home, and enables Medicare beneficiaries to use telehealth services even if they aren’t in a rural community.

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A range of health care providers, such as doctors, nurse practitioners, clinical psychologists and licensed clinical social workers, will be able to offer telehealth to Medicare beneficiaries with services. These include common office visits, mental health counseling and preventive health screenings.

For a list of frequently asked questions regarding the telehealth initiative, visit bit.ly/3bu0JmR. Additionally, CMS issued a MLN Special Edition with more guidelines (go.cms.gov/2VmrjZe) and the subsequent edit to it is published in the MLN Special Edition – Friday, April 3, 2020 (go.cms.gov/2VEZ3jw).

Medicaid Applications

Medicaid also has telehealth provisions related to COVID-19. For more information, see the Medicaid Telehealth Guidance document, released March 17 (bit.ly/3eur85J). Additionally, the AMA has created a quick guide to telemedicine in practice. It includes information on getting started; policy, coding and payment; practice implementation; and other helpful resources.

On April 23, the Trump administration issued its own telehealth toolkit to accelerate states’ use of the technology.

HIPAA Comments

The HHS Office for Civil Rights (OCR) announced it will waive potential penalties for HIPAA violations against health care providers who serve patients through widely available communication apps such as FaceTime or Skype. Officials at the OCR said the agency will exercise its enforcement discretion when providers use apps “in good faith” for any telehealth treatment or diagnostic purpose, regardless of whether the telehealth service is directly related to COVID-19. 

“In support of this action, OCR will be providing further guidance explaining how covered health care providers can use remote video communication products and offer telehealth to patients responsibly,” OCR said.

Providers are encouraged to notify patients that these third-party applications potentially introduce privacy risks, and providers should enable all available encryption and privacy modes when using such applications.

Officials noted that Facebook Live, Twitch, TikTok and similar video communication applications are public facing and should not be used to provide telehealth services, as reported in Fierce Healthcare.

A Reimbursement Lexicon

AMA, American Medical Association; CMS, Centers for Medicare & Medicaid Services; DRG, diagnosis-related group; FY, fiscal year; HHS, Department of Health and Human Services; ICD-10-CM, International Classification of Diseases, 10th Revision, Clinical Modification; IPPS, Inpatient Prospective Payment System; PFS, physician fee schedule