Additional money from Provider Relief Fund? According to the Health and Human Services (HHS) frequently-asked questions (FAQ) document on the Provider Relief Fund, providers who received payments from one or both of the first two tranches (that is, Medicare providers) can apply to HHS for additional funding. Providers can apply through the HHS portal and can receive money based on their lost revenue from March and April 2020, to the extent that the previous payments did not make up for it. Please see the FAQ for more detail on the application process. AHCA is concerned that providers could receive additional payments that HHS later decides they should not have obtained. You may wish to wait to apply until the landscape is clearer, or you may wish to apply knowing that you may have to pay back money received.
Payments to Medicaid-only providers. Upon payment of the second tranche of Provider Relief Fund grants, HHS noted that Medicaid-only providers would receive money, but it has not happened yet. The main issue is that HHS does not know who these providers are and has no other information necessary to determine and transmit payments to them. That logjam may be broken. ANCOR informed us that last Friday, the Centers for Medicare and Medicaid Services (CMS) asked state Medicaid directors to furnish specified information about all Medicaid providers in their states. This information is due tomorrow, although ANCOR indicated CMS may give states a little more time to respond. We do not know the formula, timing, or recipients for any payments, but judging from the information requested, they will be based on Medicaid revenue from 2018 and/or 2019.
More on NHSN reporting. Although the interim final rule has not yet been published in the Federal Register, AHCA informed us that CMS considers the requirements to have taken effect last Friday, May 1. The first report to the National Healthcare Safety Network (NHSN) is due by this Friday, May 8, as the reports must be made at least weekly. The first report will cover the period May 1-8 and is not retroactive to January 1. AHCA also suggested that CMS will publish another Quality, Safety, and Oversight letter this week with more details on the reporting requirements.
Requirements for day services. Today, the Department of Developmental Disabilities (DODD) convened a small group of stakeholders to review and provide feedback on a variety of draft documents related to day services operations under the current Department of Health (ODH) order. Although some day services providers have continued to provide services in settings of 10 or less, other day services providers closed in March and now plan to restart services. The department will put in place requirements for the team to discuss when determining whether a person should be authorized for day services and requirements providers need to meet in order to provide services under the order. Once these documents are finalized, OHCA will share them with members.
Billing guidance for Medicare SNF claims overlapping March/April. CMS provided the following instructions to Medicare Administrative Contractors:
Based on the following guidance from the CMS PDPM FAQs question 1.8 is to tell providers with a 5-Day PPS MDS with an April 2020 ARD, but a lookback period that extends into March 2020 that, when applicable, they can use the COVID 19 ICD-10 code U07.1 in MDS item I0020B to obtain the appropriate PDPM case-mix classification, but that the claim associated with March DOS must contain a different ICD-10 code that applies to the beneficiary and that was valid in March.
We understand that this is a one-time event that only impacts a relatively small number of admissions related to COVID-19 that spanned the March-April implementation of the new U07.1 diagnosis code. The claim will need to contain a different diagnosis other than U07.1 but the assessment may contain U07.1 code in these instances.
CMS home health and hospice telehealth clarifications. On May 1, 2020, CMS updated their frequently asked questions document on the 1135 blanket waivers, providing further clarification on use of telehealth by home health agencies. This written clarification further supports previous interpretations published by NAHC and OHCA.
For home health, the guidance specifies that only in-person visits can be reported on the claim as billable and that all telehealth visits must be ordered on the plan of care and cannot be substituted for visits ordered as in-person. The FAQ gives additional clarification on using the term “as needed” for telehealth services, using telehealth for initial assessments, and completing the comprehensive assessment.
For hospice agencies, CMS writes that only in-person visits may be reported on the claim. The FAQ allows for 2-way, audio-visual telecommunications for the initial and comprehensive assessment, but only if appropriate and feasible for the patient. Additionally, CMS gives clarification on the face-to-face requirements for telehealth visits and when telephonic telehealth visits can be used.
Please see pages 42-44 of the FAQ for additional detail on these topics.
Therapy in SNFs. Many people are wondering how the expansion of telehealth services to include therapists as eligible billing providers affects therapy delivered in a SNF. To date, we have not yet received confirmation from CMS that a SNF may report the therapy services delivered via telehealth on a claim form, as they are still not eligible billing entities for Part A or B telehealth services, although a SNF can bill an originating site facility fee. AHCA continues to seek guidance and relief on reporting therapy services.
Moreover, CMS stated in multiple recent office hours calls that a SNF may bill for therapy services furnished via audio-visual communication when the therapist is on-site but cannot see the resident face-to-face, if the services are appropriate for the resident’s care needs and in their best interest. The services are not considered telehealth because the therapist is not in a remote location, but is technically in the immediate vicinity. They should be treated and coded as if they were furnished face-to-face. The medical record should reflect how the services were furnished. This is not stated expressly in the CMS FAQ. Please contact Erin Begin with any questions on these issues.
CMS permits outpatient services in the home. In the COVID-19 Interim Final Rule released late last week, CMS states that a patient’s home now may be considered to be an off-site location - a hospital outpatient department (HOPD). These services may not be provided to patients under a home health plan of care, but this rule has the potential to impact home health admissions. Services can include wound care, drug administration, and other clinical processes.
Ohio HHA RCD update. Last Friday, Palmetto GBA hosted a call for Ohio home health agencies on the round 2 selection for Review Choice Demonstration (RCD), which opened that same day. Even though RCD submissions are optional under the public health emergency, Ohio providers still are required to submit their selection for Round 2. If you were unable to attend the webinar, please contact Erin Begin for a copy of the presentation material or join the monthly RCD call on May 6, 2020, at 11:00 a.m. by calling 866-745-0425, conference ID 6381289.
Mother's Day ideas. With Mother’s Day rapidly approaching, many SNF and assisted living residents and family members will be pressuring providers to allow visits and deliveries. OHCA put together guidance for members that includes communication to residents, their families/sponsors, and staff, considerations for drop-offs, and special events. OHCA also compiled ideas from providers in Ohio and other states. In addition, we offer a sample activity for families that providers easily can replicate.