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Tag: DSH

COVID-19 Regulatory Changes

 
President’s National Emergency Declaration; CMS COVID-19 Fact Sheet
 
For more information regarding CMS Current Emergency response and issuances, use the link below:
 
See additional COVID-19 updates below:
 
Skilled Nursing Facilities (SNFs)
CMS is temporarily waiving the following requirements for SNFs:
 
3-Day Prior Hospitalization Coverage for SNFs
For those individuals who need to be transferred as a result of an emergency related to the COVID-19 virus, Medicare will waive this requirement when the following conditions occur:
  • Evacuated from a nursing home in the emergency area;
  • Discharged from a hospital (in the emergency or receiving locations) in order to provide care to more seriously ill patients; OR
  • Need SNF care as a result of the emergency, regardless of where the individual resided
Renewal of SNF Benefit Period
Medicare beneficiaries who have recently exhausted their SNF benefits may have their SNF coverage renewed without having to start a new benefit period. The 60-day post-discharge wellness requirement for a new 100-day SNF benefit period to begin will be waived.
  • Additional SNF care related to the COVID-19 virus will be covered without requiring a break in the spell of illness
  • Individuals who had either begun or were ready to begin the process of ending their spell of illness will receive up to an additional 100 days of SNF Part A coverage
Standard MDS Timeframes Waived
CMS will waive the standard timeframe requirements for Minimum Data Set (MDS) assessments and transmissions, which are normally due at the time of admission, within 14 calendar days after admission or change in condition, and upon discharge/transfer, among others.
 
Toyon’s Take:
Providers will need to educate their clinical and billing staff on these changes. How quickly will the MACs’ billing systems be ready to accept bills containing these changes? Billing departments may expect to have claims rejected at first and to require additional help to code and resolve claims.
 
Critical Access Hospitals (CAHs)
CMS is waiving the following requirements for CAHs:
  • Limitation for the number of beds to 25
  • Limitation for the average length of stay to 96 hours
Toyon’s Take:
This waiver will allow CAHs to accept COVID-19 patients in rural areas where bed space may be scarce. How quickly can CAHs increase staffing in order to handle an increase in patients?
 
Acute Care Patients in Excluded Distinct Part Units
CMS is allowing the following changes for housing acute care patients in hospitals:
  • Hospitals may be allowed to house acute care patients in excluded distinct part units, where appropriate, as a result of this emergency
  • The patient’s medical record should be annotated to indicate that the acute care patient is being housed on an excluded unit due to the emergency

Excluded Unit Patients in Acute Care Settings

CMS is waiving the following requirements regarding care for excluded unit patient in the acute care settings of hospitals:
  • Hospitals may be allowed to house excluded distinct part IPF unit patients in acute care settings, as a result of this emergency, and continue to bill for services under the IPF PPS, where the environment is appropriate and conducive to safe care
  • Similarly, hospitals may be allowed to house excluded distinct part IRF unit patients in acute care settings, as a result of this emergency, and continue to bill for services under the IRF PPS, where the environment is appropriate, and patients continue to receive intensive rehab services
  • CMS will allow IRFs to exclude patients, who are admitted to the unit as a result of this emergency, from the IRF population for purposes of calculating the 60% threshold that is required for an IRF to maintain its special certified status
Long-Term Care Hospitals (LTCHs)
LTCHs will be allowed to exclude patient stays related to this emergency in order to meet the 25-day average length of stay requirement.
 
Toyon’s Take:
Providers will need to consider whether or not it is safe to place patients with non-psychiatric diagnoses on IPF units that house more acute psychiatric patients and vice versa.
 
Presumably, CMS will consider both misplaced acute patients on IRF units and misplaced IRF patients on acute care units when calculating the 60% threshold during this fiscal year. The appropriate coding on the claims will need to be verified in order to identify these patients.
 
Coverage and Payment Issues
CMS is making the following changes to Medicare beneficiary coverage:
  • Vaccine:  Once developed, the COVID-19 vaccine will be covered in full under Part D
  • Hospital Stays:  Patients with the virus who no longer meet the need for acute inpatient care but are being quarantined in a hospital patient room may not be charged a private room accommodation differential and will not have to pay an additional deductible for the quarantine period
  • IPPS Payment:  Medicare will pay any DRG and outlier payment, including any quarantine time, until discharge, even when the patient no longer meets the need for acute inpatient care
  • Telehealth:  Patients who have an established relationship with their physician or practitioner may have a “virtual check-in” in any healthcare facility as well as their homes, where the communication need not be related to a medical visit within the previous seven days and does not necessarily lead to a medical visit within the next 24 hours.  This expansion of services will also allow patients to access their physicians using a wider range of communication, including telephones with audio and video capabilities.  In addition, CMS is granting Medicaid waivers to cover broader telehealth services for its beneficiaries.
Toyon’s Take:

If necessary, hospitals should create a new Medicare COVID-19 private room charge in their CDMs to reflect similar charges for both private and semi-private room accommodations, when patients are diagnosed with the virus.  Unless the patient is in an ICU room, it is unlikely that the charges from additional days will generate an outlier payment.

Coverage and Payment Issues

CMS is making the following changes to Medicare beneficiary coverage:
  • Vaccine:  Once developed, the COVID-19 vaccine will be covered in full under Part D
  • Hospital Stays:  Patients with the virus who no longer meet the need for acute inpatient care but are being quarantined in a hospital patient room may not be charged a private room accommodation differential and will not have to pay an additional deductible for the quarantine period
  • IPPS Payment:  Medicare will pay any DRG and outlier payment, including any quarantine time, until discharge, even when the patient no longer meets the need for acute inpatient care
  • Telehealth:  Patients who have an established relationship with their physician or practitioner may have a “virtual check-in” in any healthcare facility as well as their homes, where the communication need not be related to a medical visit within the previous seven days and does not necessarily lead to a medical visit within the next 24 hours.  This expansion of services will also allow patients to access their physicians using a wider range of communication, including telephones with audio and video capabilities.  In addition, CMS is granting Medicaid waivers to cover broader telehealth services for its beneficiaries.
Toyon’s Take:

If necessary, hospitals should create a new Medicare COVID-19 private room charge in their CDMs to reflect similar charges for both private and semi-private room accommodations, when patients are diagnosed with the virus.  Unless the patient is in an ICU room, it is unlikely that the charges from additional days will generate an outlier payment.

Provider Enrollment
CMS will be making the following changes to the provider enrollment process:
  • Waiver of application fee
  • Waiver of site visits
  • Postponement of all revalidation actions
  • Allow licensed providers to render services outside of their state of enrollment
  • Expedited pending or new applications from providers
Toyon’s Take:
Even though many of the steps in the standard provider enrollment process may be temporarily waived, providers should be prepared for CMS and State Agencies to revisit these applications and perform a more thorough follow-up review, after this emergency has passed. Providers should maintain all documentation related to any provider enrollment action until that follow-up review is conducted should that be necessary.
 
Medicaid Programs
CMS is allowing states the flexibility to make changes, such as the following examples:
  • Waive prior authorization requirements for fee-for-service programs
  • Permit providers located out of state to provide care to another state’s Medicaid enrollees who are impacted by this emergency
  • Temporarily suspend certain provider enrollment and revalidation requirements
  • Temporarily waive requirements that physicians and other healthcare professionals be licensed in the state in which they are providing services, so long as they have an equivalent license in another state
  • Temporarily suspend requirements for certain pre-admission and annual screenings for nursing home residents
States can assess their needs in the Medicaid Response Toolkit.
 
COVID-19 Testing: HCPCS U0001 / HCPCS U0002
Beginning April 1, providers can bill Medicare and other insurers for COVID-19 testing provided on or after Feb. 4 using the following Healthcare Common Procedure Coding System (HCPCS) codes:
  • HCPCS U0001 – Medicare will reimburse approximately $36 to allow providers to bill for using CDC’s RT-PCR Diagnostic Test Panel
  • HCPCS U0002 – Medicare will reimburse approximately $51 for validated, in-house developed COVID-19 diagnostic tests.
Please refer to the link below for COVID-19 Test Pricing by MAC jurisdiction:
 
Other Recently Published Rules
 
Interoperability and Patient Access Final Rule [CMS-9115-F]
(FR Publish Date TBD)
  • Improved exchanges for dually eligible patients, which will change from monthly to daily (beginning April 1, 2022)
  • CMS will begin publicly reporting hospitals and clinicians that may be blocking information, based on their EHR attestations (late 2020)
  • CMS is modifying provider CoPs to require that electronic event notifications of a patient’s admission, discharge, and/or transfer be sent to healthcare facilities or practitioners in an effort to improve coordination of care (effective 6 months after publication of this Final Rule)

This information was current as of the time it was published.

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COVID-19 President’s National Emergency Declaration CMS Fact Sheet

President’s National Emergency Declaration; CMS COVID-19 Fact Sheet
 
On March 13, 2020, the Centers for Medicare & Medicaid Services (CMS) published a fact sheet that outlines the impacts to healthcare providers from President Trump’s national emergency declaration. CMS is empowered to take proactive steps through 1135 waivers and rapidly expand the Administration’s aggressive efforts against COVID-19.
 
Overall, these regulatory changes are focused on addressing the potential shortage of beds needed to address the infected population. It appears that excess patient load may now be pushed into any available bed, including post-acute care settings by waiving patient and facility requirements. These changes appear to be effective immediately.
 
For more information regarding CMS Current Emergency response and issuances, use the link below:
 
 
Toyon’s Take on Hospital Charity Policies During the Emergency
As demand increases, providers should prepare for an influx of patients who are underinsured with high deductible health plans, or one of over 27 million Americans without health coverage. As hospitals care for these patients, it is important any corresponding patient discounts are specified in the patient financial assistance policy (FAP). If providers are loosening FAP requirements for care related to COVID-19 testing or treatment, it is recommended the FAP is updated to include this coverage. Specification in the FAP allows for uncompensated care cost recognition and payment for DSH providers.
 
Toyon is committed to keeping providers informed and will continue to send important updates as they unfold.

Respectfully,

Toyon Associates, Inc.
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Uncompensated Care Recognition Services–Important DSH Update

Now is the time to amend FY 2018 uncompensated care (UC).  FY 2018 is currently under audit and likely to impact future UC DSH payments.

Action Requested
Please be on the lookout for correspondence from your Medicare auditor regarding FY ‘18 worksheet S-10 uncompensated care (UC) cost (e.g., 9/30/18, 12/31/18, 6/30/19).    

We are here to help
Now is the time to amend 2018 UC cost amounts so that all allowable costs are recognized for future payments.  Toyon’s Uncompensated Care Recognition Service is the industry leader for UC DSH reporting.  For a dashboard evaluation of your hospital’s projected UC DSH payments and cost, please contact Fred Fisher at 888.514.9312, fred.fisher@toyonassociates.com.

Timeline and Toyon’s Take
Based on CMS’s current trend of auditing worksheet S-10 UC cost, it is very likely in these audits will impact FFY 2022 UC DSH payments.  Hospitals in receipt of these audit letters were given a deadline of March 25 to provide detailed patient listings supporting FFY 2018 UC cost amounts reported on Worksheet S-10.  Toyon recommends all DSH hospitals with FY ‘18 S-10 revisions, including those not in receipt of the audit letter, contact their MAC to set shared expectations.  Please feel to reach out to Toyon’s UCRS team for help or to answer any questions. 

Respectfully, 

Toyon Associates, Inc.

www.toyonassociates.com

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