By George W. Chapman
In late April, the Centers for Medicare & Medicaid Services (CMS) issued radical changes to combat the COVID-19 pandemic. The Coronavirus Aid, Relief, and Economic Security Act expands beneficiary coverage for the virus and gives providers greater flexibility in delivering care. Some of the important provisions are summarized below. It should be noted that CMS rules pertain to Medicare and Medicaid beneficiaries. However, most commercial carriers tend to mimic CMS especially during this pandemic. If you are covered by a commercial plan, to be sure about coverage, contact them first.
You do not need a written order from your treating physician to get tested for the virus. An order (it does not have to be written) from any qualified healthcare practitioner authorized to do so under state law will be accepted. Pharmacies can do testing if enrolled with CMS as a lab. Beneficiaries can now be tested in so called “parking lot” sites operated by qualified entities such as hospitals, community health centers, pharmacies, etc. CMS will pay for the services related to the virus in full. The beneficiary will not be responsible for any deductible or co-pay.
Hospitals are allowed to temporarily increase their number of beds to accommodate COVID-19 patients. Inpatient psychiatric and rehab facilities may admit COVID-19 patients to relieve the pressure on hospitals. CMS has made it easier for inter-facility transfers.
Advanced practitioners (nurse practitioners, physician assistants, clinical nurse specialists) can provide home health care without physician certification. APs can order the services, establish care plans and certify that the patient is eligible for home care. Teaching hospitals are allowed to send available residents to other affiliated or non-affiliated hospitals to help out. Physical and occupational therapists can delegate routine maintenance services to their qualified assistants. During the COVID-19 emergency, hospitals and ambulatory surgery centers will not have to periodically reappraise staff privileges. This allows them to keep providers whose privileges would normally be expiring. It also allows them to temporarily bring retired physicians back.
Mental health delivery
CMS will allow and pay for individual psychotherapy, education and group psychotherapy that are delivered in temporary expansion locations, including the patient’s home. Normally, patients would be required to receive these services at the community clinic.
These temporary changes will most likely have the most profound and enduring impact on the delivery of care far beyond the pandemic. Up until the pandemic, telehealth was used sporadically and traditional face to face encounters were preferred. Red tape and low payment discouraged both physicians and patients from using telehealth. CMS and commercial carriers have long feared the easy use of telehealth would merely increase utilization without any real impact on outcome. As the pandemic lingers, both consumers and providers are adapting to telehealth. Most likely, some of these temporary changes below will become permanent.
Physical, occupational and speech therapists can provide services via telehealth. Hospitals may provide and bill, as the originating site, for telehealth services provided to registered outpatient in their home. The patient’s home becomes an extension of the hospital’s outpatient department. Services provide remotely include counseling, education and therapy. Telehealth may be provided by audio only (telephone) versus audio and visual. Medicare is now covering some services when provided as audio only — this includes behavioral and patient education services. CMS has (finally) increased payments to providers for telephone encounters to match payments for traditional office visits. This is retroactive to March 1. CMS has promised to add to the list of approved telehealth services and to accelerate the approval process on a “sub-regulatory” basis. (As providers and consumers adapt, I think it will be very difficult for CMS to go backwards on telehealth once the pandemic subsides.) CMS is now paying rural clinics and federally qualified community health centers for providing telehealth services.
CMS is allowing physicians, licensed in a particular state, to bill for telehealth services provided to their patients who may live across state lines.
George W. Chapman is a healthcare business consultant who works exclusively with physicians, hospitals and healthcare organizations. He operates GW Chapman Consulting based in Syracuse. Email him at firstname.lastname@example.org.