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COVID-19 Updates

What to expect when the COVID-19 public health emergency ends

The public health emergency began on January 31, 2020.  It is currently set to expire on July 24.  Here are the special programs and waivers with the dates they will end:

Programs:                

  • Accelerated and Advance Payments program ended April 26.
  • Round 1 General Allocation Relief Funds:  these funds have been distributed; providers who accepted the funds are required to waive the patient out-of-network cost for dates of service March 18 through July 24.  After July 24, patients can be billed for out-of-network fees.
  • Round 2 General Allocation Relief Funds:  only available to providers who accepted Round 1 Relief Funds; must have submitted additional revenue information by June 3 to receive these funds
  • Uninsured COVID-19 Patient program:  this program is currently scheduled to continue until the funds are exhausted.

Waivers:

  • The Federal Waiver that allows licensed practitioners in one state to practice in other states without fully licensing in that state will end July 24.
  • All waiver of copays, coinsurance & deductibles for COVID-19 patients will end with July 24 dates of service, unless the payer opts for a later date of service.  For instance, United HealthCare is waiving copays and deductibles through September 30.
  • Waiver that allows payment of transports to Alternative Destinations, such as urgent care, physician offices and COVID facilities will expire July 24.
  • Waiver that allows verbal consent by the patient to replace a patient signature on the billing authorization expires July 24.
  • Medicare sequestration of 2% is waived from May 1 through December 31.  It will resume on claims with dates of service beginning January 1, 2021.

Washington State Programs:

  • WA Medicaid temporarily increased payment for Medicaid patients with suspected or confirmed COVID beginning with dates of service 2/29/2020.  All payments will return to the current fee schedule when Washington State discontinues the state of emergency.
  • WA GEMT temporarily increased the cost-per-transport for claims with an FMAP of 50% or 65%.  This applies to dates of service January 1 through June 30, 2020.

You may find additional information from United HealthCare by clicking here and here.

Round 2 of HHS Funding for Healthcare Providers – What ambulance providers need to know

Applying for money from the $20 Billion for General Allocation Relief Fund
You must have accepted Round 1 funding and completed the attestation (Portal Link).
Complete the User Application Guide (Link).
In the application portal (link), you will need:

  • Tax ID Number
  • Bank account number into which the first round of relief funding was deposited
  • Dollar amount of first round (Tranche 1) deposit
  • Email account you’re using on the application
  • PDF copy of your most recent tax return, 990 (if non-profit), or most recent audited financial statements or other reporting if you are a governmental agency (see FAQ link).

Funds are released every Friday. The sooner you complete the validation, the sooner you will receive your payment. 

Part of this application involves an estimate of your lost net revenue from March and April 2020 dates of service. Providers should have a fact-based, reasonable way to make this estimate. You should also document your calculation method and your fact base.

Reimbursement for the testing and treatment of uninsured COVID-19/COVID-19 presumptive patients
HHS will reimburse for testing and treatment of uninsured COVID or COVID presumptive patients for emergency and non-emergency ground ambulance transports, and any testing performed. To qualify, a provider must:

  1. Reasonably know that the patient is truly uninsured (SDW will document its insurance searches).
  2. Accept program’s reimbursement as payment in full.
  3. Not balance bill COVID-19 patients
  4. Abide by Terms & Conditions of Relief Funding, including a potential post-payment review (audit)

The timeline for the program is as follows:
April 27: Sign up period begins. This must be completed by the provider and cannot be done by SDW – we do not have the authority to do this on your behalf.
April 29: On-demand training opens for claims submission.
May 6: Begin submitting claims electronically.
Mid-May: Reimbursement begins. 

HERE is a link to the program website, including the registration, FAQ, and overview. 

Reimbursement will be made for: qualifying testing for COVID-19 and treatment services with a primary COVID-19 diagnosis, including the following:

  • Specimen collection, diagnostic and antibody testing.
  • Testing-related visits including in the following settings: office, urgent care or emergency room or via telehealth.
  • Treatment: office visit (including via telehealth), emergency room, inpatient, outpatient/observation, skilled nursing facility, long-term acute care (LTAC), acute inpatient rehab, home health, DME (e.g., oxygen, ventilator), emergency ground ambulance transportation, non-emergent patient transfers via ground ambulance, and FDA approved drugs as they become available for COVID-19 treatment and administered as part of an inpatient stay.

 Services not covered by traditional Medicare will also not be covered under this program. In addition, the following services are excluded:

  • Air and water ambulance.
  • Any treatment without a COVID-19 primary diagnosis, except for pregnancy when the COVID-19 code may be listed as secondary.

 All claims submitted must be complete and final. The program begins retroactively to February 4, 2020, and extends until the Public Health Emergency ends.

There is speculation these funds for uninsured patients will run out, so it is important that you register ASAP and that Systems Design West has your claims in-house and ready to submit on May 6th. Presumably you must have participated in the other parts of the HHS funding to participate in this, although it is unclear at this time. 

Your clear documentation of suspected COVID-19 patients is critical in our ability to be able to route these claims correctly in these new programs. Please continue to monitor your crews’ documentation for billing. 

Governmental and municipal agencies may want to consider attending this American Ambulance Association webinar for additional information on all of the funding sources available to them at this time. 

Disclaimer: Systems Design West provides this information to be a helpful resource to providers, however each provider is solely responsible for understanding the programs in which it will be participating and abiding by the terms and conditions associated with all.

Attestation Portal Now Available for HHS Payments from CARES Act Provider Relief Funds

As mentioned in our communication earlier this week, the CARES Act Provider Relief Fund has begun its disbursement to providers.

All recipients who intend to keep the funds are required to complete the attestation.

HERE is a link to the attestation portal. You must do this if you keep the funds.

HERE is a link to the SDW survey letting us know to adjust your policies in compliance. You must complete this for us to keep your billing practices in compliance.

HERE is a link to the HHS page with more information about this program.

Our earlier communication is listed below, for your reference.

_____________________________________________________________

As some of you may be aware, the CARES Act Provider Relief Fund allows for the immediate delivery of $30 billion into the healthcare system.  This letter summarizes important pieces of information for your understanding and your requirement by accepting the funds.

Distribution of these funds will begin as early as April 10, 2020 via direct deposit.  These are payments, not loans, to healthcare providers, and will not need to be repaid.

All providers: Click HERE to fill out this brief survey

Providers will be distributed a portion of the initial $30 billion based on their share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019.

Providers will be paid via Automated Clearing House account information on file with UHG or the Centers for Medicare & Medicaid Services (CMS).

  • The automatic payments will come to providers via Optum Bank with “HHSPAYMENT” as the payment description.
  • No notification will be sent to Systems Design.
  • Providers who normally receive a paper check for reimbursement from CMS, will receive a paper check in the mail for this payment as well, within the next few weeks.

Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. The portal for signing the attestation will be open the week of April 13, 2020 and will be linked on the attachment.

As a condition to receiving these funds, providers must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.  If a provider receives payment and does not wish to comply with these Terms and Conditions, the provider must do the following: contact HHS within 30 days of receipt of payment and then remit the full payment to HHS as instructed.  Appropriate contact information will be provided soon.

For more information on the CARES Act click here.

For questions about this communication or the survey, please call Systems Design West at 1-800-585-5242 or email admin@sdwems.com.

Information Regarding Payments from the CARES Act Provider Relief Fund

As some of you may be aware, the CARES Act Provider Relief Fund allows for the immediate delivery of $30 billion into the healthcare system.  This letter summarizes important pieces of information for your understanding and your requirement by accepting the funds.

Distribution of these funds will begin as early as April 10, 2020 via direct deposit.  These are payments, not loans, to healthcare providers, and will not need to be repaid.

All providers: Click HERE to fill out this brief survey

Providers will be distributed a portion of the initial $30 billion based on their share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019.

Providers will be paid via Automated Clearing House account information on file with UHG or the Centers for Medicare & Medicaid Services (CMS).

  • The automatic payments will come to providers via Optum Bank with “HHSPAYMENT” as the payment description.
  • No notification will be sent to Systems Design.
  • Providers who normally receive a paper check for reimbursement from CMS, will receive a paper check in the mail for this payment as well, within the next few weeks.

Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. The portal for signing the attestation will be open the week of April 13, 2020 and will be linked on the attachment.

As a condition to receiving these funds, providers must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.  If a provider receives payment and does not wish to comply with these Terms and Conditions, the provider must do the following: contact HHS within 30 days of receipt of payment and then remit the full payment to HHS as instructed.  Appropriate contact information will be provided soon.

For more information on the CARES Act click here.

For questions about this communication or the survey, please call Systems Design West at 1-800-585-5242 or email admin@sdwems.com.

UPDATED Coronavirus Aid, Relief, and Economic Security (CARES) Act

All of us at SDW are so grateful for your service to our communities during these times that previously were impossible to imagine. We are proud to support you and do all that we can to make sure your organization has its revenue and backend patient care well in-hand. 

There are many new programs, acts, laws, and discussions aimed at helping seemingly everyone, including ambulance providers, weather this storm. This communication is meant to highlight some elements of recent changes to make you aware of what could be impactful to ambulance providers.  

Please see this document from CMS titled “CMS Flexibilities to Fight COVID-19” for more information on transporting to Temporary Expansion Sites, Documentation, Accelerated/Advance Payments, Enrollments, and more.

Coronavirus Aid, Relief, and Economic Security (CARES) Act as related to EMS: 

  • Suspends Medicare sequestration, meaning a 2% increase in Medicare payments, beginning with May 1st dates of service through Dec 31, 2020 
  • Suspends prior authorization requirements for Medicare; individual states may choose to adopt this waiver and change prior authorization standards for their Medicaid programs 

As a blanket waiver, some Medicare enrollment requirements have been loosened or expedited for providers.  

Medicare is also creating an avenue where providers enrolled with CMS can access Accelerated and Advanced Payments. Please go here for more information: 

Several additional requests for waivers have been submitted to Medicare and are retroactive back to March 1, 2020

  • Medicare has approved expansion of the list of covered destinations during the current public health emergency.  Ambulance transportation is now covered to all destinations that are equipped to treat the condition of the patient, based on state/local laws where the transport is furnished.  This includes alternative sites that are part of a hospital or skilled nursing facility, as well as community mental health, federal qualified health clinic, rural health clinics, physician offices, urgent care facilities, ambulatory surgery centers and any location providing dialysis when an ESRD facility if not available. 

This expansion covers both emergency and non-emergency transports however, transports are still required to meet medically necessary.  Medicare has been asked to confirm that patients who require isolation meet medical necessity requirements, and we are awaiting an answer. 

  • Medicare has confirmed that during the public health emergency, patient signatures will not be required.   
  • Telehealth services are normally provided by practitioners working under the supervision of a physician.  Medicare has waived the “direct supervision” requirements during the current public health emergency and is allowing physicians to contract with ambulance agencies, using their personnel to provide telehealth services.   The physician would bill for the telehealth services and reimburse the ambulance agency according to contract. 
  • Still Pending Decision:  Allow for payment of Treat, No Transport/Treatment in Place.   AAA requested this waiver on March 11th and while Medicare initially responded that they do not believe they have the authority to allow payment of non-transports, the request is still pending.   
  • Still Pending Decision:  Allow transport of suspected or confirmed COVID patients to meet ambulance medical necessity. 

Each State’s Medicaid office is having its own discussions on what can be done at this time. For example, in WA there is discussion of increasing the fee schedule and expanding requirements on the existing Treat-and-Refer program. It may take time for any changes to materialize, however we are tracking closely. 

One key theme we have gleaned is that good documentation and cost tracking is critical to accessing other emergency funds. We encourage our clients to review the FEMA Category B Emergency Protective Measures Public Assistance Program to see what costs FEMA funds may cover. For clients selected for the first year of Medicare Cost Data Collection, there may be revisions to the cost report to account for costs incurred because of this crisis. Again, good documentation and cost tracking of all coronavirus activities is encouraged.  

Good documentation will also be needed in any patient care report where the patient is suspected or confirmed to have COVID-19.  We will be tracking these claims through the billing process and using all approved waivers to correctly bill, receive payment and appeal denials.  The report needs to clearly document an impression or assessment of COVID-19 and the associated signs and symptoms.  This information greatly improves our ability to collect payment. 

Coronavirus Aid, Relief, and Economic Security (CARES) Act

Dear Systems Design West clients,

All of us at SDW are so grateful for your service to our communities during these times that previously were impossible to imagine. We are proud to support you and do all that we can to make sure your organization has its revenue and backend patient care well in-hand.

There are many new programs, acts, laws, and discussions aimed at helping seemingly everyone, including ambulance providers, weather this storm. This communication is meant to highlight some elements of recent changes to make you aware of what could be impactful to ambulance providers.

Coronavirus Aid, Relief, and Economic Security (CARES) Act as related to EMS:
Suspends Medicare sequestration, meaning a 2% increase in Medicare payments, beginning with May 1st dates of service through Dec 31, 2020

Suspends prior authorization requirements for Medicare; individual states may choose to adopt this waiver and change prior authorization standards for their Medicaid programs

As a blanket waiver, some Medicare enrollment requirements have been loosened or expedited for providers.

Medicare is also creating an avenue where providers enrolled with CMS can access Accelerated and Advanced Payments. Please go here for more information: https://www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf

Several additional requests for waivers have been submitted to Medicare and our understanding is that these are currently pending a decision:

Allow for payment of transports to alternative destinations, such as primary care, urgent care, mental health facilities and COVID-19 sites. This waiver has been requested for both emergency and non-emergency transports. If approved, good documentation about WHY the alternative destination was necessary will be required.

Allow for payment of Treat, No Transport/Treatment in Place. AAA requested this waiver on March 11th and while Medicare initially responded that they do not believe they have the authority to allow payment of non-transports, the request is still pending.

Waive patient signature requirements for ambulance suppliers. Many of you have asked about patients signing the Billing Authorization form, either on a tablet or on paper, and the associated infection control problems. While this requested waiver is pending, you can access recent guidance (https://www.pwwemslaw.com/sites/default/files/forms/pww-covid-19-ems-resources/pww-statement-assignment-benefits-signatures-ems-practitioners.pdf) on how documentation might describe suspected COVID 19 patients who are physically or mentally incapable of signing. 

Allow transport of suspected or confirmed COVID patients to meet ambulance medical necessity.

Each State’s Medicaid office is having its own discussions on what can be done at this time. For example, in WA there is discussion of increasing the fee schedule and expanding requirements on the existing Treat-and-Refer program. It may take time for any changes to materialize, however we are tracking closely.

One key theme we have gleaned is that good documentation and cost tracking is critical to accessing other emergency funds. We encourage our clients to review the FEMA Category B Emergency Protective Measures Public Assistance Program to see what costs FEMA funds may cover. For clients selected for the first year of Medicare Cost Data Collection, there may be revisions to the cost report to account for costs incurred because of this crisis. Again, good documentation and cost tracking of all coronavirus activities is encouraged.

Good documentation will also be needed in any patient care report where the patient is suspected or confirmed to have COVID-19. We will be tracking these claims through the billing process and using all approved waivers to correctly bill, receive payment and appeal denials. The report needs to clearly document an impression or assessment of COVID-19 and the associated signs and symptoms. This information greatly improves our ability to collect payment.