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COVID-19 Updates

Attention All Providers: New Phase 3 Provider Relief Funding Available

The U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), has announced $20 billion in new funding for providers on the frontlines of the Coronavirus (COVID-19) pandemic. Under this Phase 3 General Distribution allocation, providers that have already received Provider Relief Fund payments may apply for additional funding that considers financial losses and changes in operating expenses caused by the COVID-19 pandemic. Previously ineligible providers, such as those who began practicing in 2020, are invited to apply
Providers eligible for Phase 3 General Distribution funding include:

  • Providers who previously received, rejected, or accepted a General Distribution Provider Relief Fund payment. Providers that have already received payments of approximately 2% of annual revenue from patient care may submit more information to become eligible for an additional payment, but preference will be given to providers who have received payments of less than 2% to date.
  • Healthcare providers that began practicing January 1, 2020 through March 31, 2020.

Providers will have from October 5, 2020, through November 6, 2020, to apply for Phase 3 General Distribution funding.
Please visit the U.S. Department of Health & Human Services website at: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html for details on how to apply.  You may also wish to register for the webcast offered on 10/15/20 at 12 PM PT. Financial information regarding operating revenue and expenses, as well as tax returns or equivalent from tax-exempt entities are required. The details may be found here: https://www.hhs.gov/sites/default/files/provider-distribution-instructions.pdf


Even if you choose not to apply for additional funds, please review the Provider Relief Fund FAQ page https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/index.html for more info about the terms and conditions of Round 1 and 2 grants as well as the reporting requirements that will be coming due in the near future. Systems Design West will continue to administer the balance billing waivers for the duration of the public health emergency. However, when you have exhausted your Provider Relief Funds, you are no longer obligated to waive balance billing, so please inform SDW in writing when that happens.  

Reporting Requirements for Agencies that Received HHS Provider Relief Funds from the CARES Act

Between April 10th and 17th, HHS deposited CARES Provider Relief Funds directly into ambulance providers bank accounts. The size of these payments was determined by the percentage of Medicare payments in the year prior. At the time of deposit, the provider obligations were to either accept the funds and sign the attestation or reject the funds and send them back. If you did neither, it was assumed that you agreed to the Terms & Conditions associated with the funds. SDW reached out to every client individually regarding the funds to make sure you knew they were there and to make a conscious choice about accepting or rejecting based on the Terms & Conditions.

HHS recently released guidance on the reporting requirements for agencies that received greater than $10,000. The new reporting requirements can be found here. Items you will have to report include demographic information about your organization, expenses related to COVID-19 that were not reimbursed by other sources, lost revenues related to COVID-19, staffing metrics and patient encounters.

If an agency uses all funds received by 12/31/2020, the report is due within 45 days of the new year (February 12, 2021). If the agency has leftover funds on 12/31/2020, the agency has an additional 6 months to use the remaining funds, and the report will be due on July 31, 2021.

Please read the Post-Payment Reporting Notice carefully so you know what to expect when more information becomes available. For those who received greater than $10,000 and are subject to these reporting requirements, Systems Design West is prepared to help specifically with the lost revenues portion of the reporting. Systems Design West will continue to keep you informed of any updates as they become available.

Breaking News on the CARES Act

PWW has issued information on a major change to the reporting requirements for agencies who received COVID-related relief funds. While there are currently many unanswered questions, Systems Design will pass along new information as it comes available. Here is the news release from PWW:

The Reporting Deadline is Coming and the Threshold has Dropped 

The CARES Act Terms & Conditions The first round of CARES Act stimulus funds was deposited without any action being required on your part.  You were required to accept certain Terms and Conditions if you applied for additional funding in round two.  But even if you did not check a box or sign an agreement, if you did not return the money, you automatically accepted the Terms and Conditions which were attached to it.  Now, one of those conditions is coming into play.
The Terms and Conditions of the CARES Act provider stimulus payments includes a requirement for those receiving more than $150,000 to submit reports to the Committee, and others to report “as required by the Secretary”.  The Secretary of HHS has now expanded who will be required to account for CARES Act and other COVID-related relief funds, and the threshold for reporting is going to be much lower.  


The $150k reporting threshold plummets to $10k
The reporting, which will begin in January of 2021 for all funds received and spent in 2020, will be required of all who have received a total of $10,000 or more. The Terms state that this includes any funds received from HHS under the Coronavirus Aid, Relief, and Economics Security Act (“CARES”), the Coronavirus Preparedness and Response Supplemental Appropriations Act, the Families First Coronavirus Response Act, or any other Act primarily making appropriations for the coronavirus response.  Therefore, this lowered threshold will likely mean that almost every EMS and ambulance agency will have to follow the reporting requirements.

What will reporting look like? When we contacted the Pandemic Response Accountability Committee about these reports, the response we received stated: “Under the CARES Act, each agency is responsible for providing user-friendly means for covered recipients to meet requirements of this subsection.The Committee is coordinating with agencies regarding this requirement.” This coordination is an on-going process, and the most recent announcement still does not have all of the answers.  However, more details about how this reporting will look are to be announced on August 17 th. We anticipate that reporting will be accomplished through an online portal with question-driven data entry. While we do not know exactly what this portal will look like or what questions they may ask, we do know what the Terms and Conditions state. According to the Terms, reports shall contain:  

  1. the total amount of funds received from HHS under each of the foregoing enumerated Acts;
  2. the amount of funds received that were expended or obligated for each project or activity;
  3. a detailed list of all projects or activities for which large covered funds were expended or obligated, including: the name and description of the project or activity, and the estimated number of jobs created or retained by the project or activity, where applicable; and
  4. detailed information on any level of sub-contracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees, to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 allowing aggregate reporting on awards below $50,000 or to individuals, as prescribed by the Director of the Office of Management and Budget.

Stay Tuned…
The threshold has changed who will be required to report, so a change in what will be required to report should certainly not come as a surprise. We will know more after August 17th, and there may even be an opportunity to raise questions and objections that ultimately affect the final reporting requirements, so watch for future announcements from PWW. 

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

Updated July 2, 2020

The public health emergency (PHE) began on January 31st, 2020.  While it is currently set to expire on July 25th, there are recent indications that the PHE will be extended for an additional 90 days.  While not an official statement, the spokesperson for HHS tweeted that the department “expects to renew” the current PHE for COVID-19.  An extension would be good news for healthcare providers.

Click here to see a report on the unofficial statement from HHS.

Many of the waivers and flexibilities currently available for COVID-related services base their start and end dates on two declarations—the public health emergency mentioned above and the President’s emergency declaration on March 13, 2020 under the National Emergencies Act (NEA).   The NEA declaration can be terminated at any time by presidential proclamation or by a Congressional joint resolution.

Both declarations, PHE and NEA, need to be active for the following waivers and flexibilities: 

  1. Waiver that allows licensed practitioners in one state to practice in other states without fully licensing in that state
  2. Waiver that allows payment of transports to alternative destinations, such as urgent care, physician offices and COVID facilities
  3. Waiver that allows verbal consent by the patient to replace a patient signature on the billing authorization

The following programs are dependent on the Public Health Emergency declaration only, which is slated to end July 25th, but could be extended an additional 90 days:

  1. CARES Act General Allocation Relief Funds, Round 1 and Round 2:  Providers who accepted funds from Round 1 or Round 2 are required to waive patient out-of-network costs, starting with dates of service March 18, 2020.  After the PHE ends, patients can be billed for out-of-network fees.
  2. Uninsured COVID-19 Patient program:  this program is currently scheduled to continue until the funds are exhausted.
  3. Most commercial insurance plans are waiving patient copays, coinsurance & deductibles for COVID-19 patients through the end of the PHE, unless the payer opts for a later date of service.  For instance, United HealthCare is waiving copays and deductibles through September 30th.

Click here for more details on health insurance plan actions.

Washington State Programs:

  1. 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 terminates the state of emergency.
  2. WA GEMT temporarily increased the cost-per-transport for claims with an FMAP of 50% or 65%.  This applies to dates of service January 1st through June 30th, 2020.

Miscellaneous Changes:

  1. Medicare sequestration of 2% is waived from May 1st through December 31st.  It will resume on claims with dates of service beginning January 1, 2021.
  2. Ambulance providers scheduled to submit cost data reporting in 2020 have the option to delay until 2021.

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.