CMS Issued Extensive Updates to its Medicare Billing FAQs

CMS updated the COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing  by adding or updating the following numerous FAQs for the following areas of billing:

  • Laboratory Diagnostic Services, FAQs 9-13.
  • Hospital Outpatient – Locations Off Campus, FAQs 2-17
  • Hospital Outpatient Therapeutic Services Furnished In Temporary Expansion Locations, FAQs 1-3
  • Partial Hospitalization Program (PHP) Services, FAQs 1-3
  • Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs), FAQs 12-15
  • Medicare Telehealth, FAQs 2-4, 15, 23, 36-42
  • Scope of Practice (All New!), FAQs 1-4
  • Additional Flexibility under the Teaching Physician Regulations (All New!), FAQs 1-5
  • Medicare Shared Savings Program – Accountable Care Organizations (ACO), FAQs 10-27
  • Opioid Treatment Programs (OTPs), FAQ 3
  • Inpatient Rehabilitation Facility Services, FAQs 2-10
  • Skilled Nursing Facility Services, FAQs 5-6
  • Home Health, FAQs 7-13
  • Durable Medical Equipment Interim Pricing in the CARES Act (All New!), FAQs 1-6
  • Medical Education (All New!), FAQs 1-4
  • Applicability Dates of Provisions in Second Interim Final Rule with Comment Period (IFC) (All New!), FAQ 1

The latest FAQs have a “New” or “Updated” date of 6/19/20.

CMS Extends Inpatient Prospective Payment System (IPPS) Wage Index Occupational Mix Survey Submission

CMS collects data every 3 years on the occupational mix of employees for each short-term, acute care hospital participating in the Medicare program. Completed 2019 Occupational Mix Surveys, Hospital Reporting Form CMS-10079, for the Wage Index Beginning FY 2022, are due to the Medicare Administrative Contractors (MACs) on the Excel hospital reporting form by July 1, 2020. CMS is currently granting an extension for hospitals nationwide affected by COVID-19 until August 3, 2020. If hospitals encounter difficulty meeting this extended deadline date, hospitals should communicate their concerns to CMS via their MAC, and CMS may consider an additional extension if CMS determines it is warranted.

HHS Announces Acquisition of Remdesivir for Purchase by US Hospitals

On June 29, 2020, HHS announced an agreement to secure more than 500,000 treatment courses of the drug remdesivir for the United States from Gilead Sciences through September, allowing American hospitals to purchase the drug at the Wholesale Acquisition Cost (WAC) of approximately $3,200 per treatment course.  Additional supplies of remdesivir have been obtained for clinical trials. HHS will allocate the remdesivir to state health departments based on the state’s COVID-19 hospital burden, and health departments will allocate it to hospitals. The delivery of the purchased remdesivir will be streamlined, shipping directly from AmerisourceBergen to hospitals, about every two weeks.  Previously, remdesivir has been donated by Gilead Sciences to HHS; however, the last of HHS’s donated supply was distributed to hospitals earlier this week.

HHS Expects to Renew Public Health Emergency

While the Public Health Emergency (PHE) due to COVID-19 is set to expire on July 25, 2020, on June 29th, an HHS spokesperson confirmed that HHS intends to renew it.  Amidst growing concerns that it may expire, the American Hospital Association sent a letter to the Secretary of HHS urging renewal.  In response, Michael R. Caputo, HHS Assistant Secretary for Public Affairs, tweeted:  “Enough already. [HHS] expects to renew the Public Health Emergency due to COVID-19 before it expires.”

Providers also expressed concerns about how to calculate expected lost revenues and increased costs “during the COVID-19 PHE” for purposes of the CARES Act Provider Relief Fund grants.  According to a Modern Healthcare story  (accessible only to subscribers), an HHS spokesperson responded that the term “during the COVID-19 PHE” was not meant to be restrictive and may not be limited to the official PHE dates.  In addition, according to a March 31, 2020 FEMA Memo, providers can submit Requests for Public Assistance (RPAs) to FEMA for 30 days after the end of the declaration of the PHE.

The PHE, which lasts for 90 days, was originally declared on January 31, 2020, and renewed once already on April 26th.

Kentucky Phased Resumption of Group Activities, Communal Dining, Off-Site Appointments and Visitation at LTC Facilities

On June 25, 2020, the Kentucky Cabinet for Health & Family Services (CHFS) provided guidance to long term care providers concerning the resumption of certain activities. Beginning June 29, all long term care facilities may resume recreational and therapeutic group activities, communal dining, and transportation for non-emergent off-site appointments—as long as certain prerequisites are met and safeguards are in place.  Assisted Living Communities, Licensed Personal Care Homes and Family Care Homes may resume limited visitation starting June 29, while Skilled Nursing Facilities (SNF), Nursing Facilities (NF), Nursing Homes (NH) and Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF-IID) may start limited visitation on July 15.  For additional details, please refer to  Phased Reduction of Restrictions for Long Term Care Facilities.