CorroHealth Weekly eJournal, May 10, 2023

Facility Billing After The PHE

Background

During the COVID-19 Public Health Emergency (PHE), hospitals and practitioners were granted certain ?flexibilities?to meet the healthcare needs of the country under waivers issued by the federal government. In addition, some healthcare services related to COVID vaccinations, screening for COVID, and treating COVID-positive patients were given special coverage by Medicare and Congress to protect the patient from incurring financial liability This paper offers concise guidance on coding and coverage changes which apply to hospitals following the end of the Public Health Emergency on May 11, 2023.

COVID PCR and Ant igen Test Orders

After the PHE, Medicare will require all COVID-19 and related testing that is performed by a laboratory to be ordered by a physician or non-physician practitioner.

COVID Ant ibody (serology) Test s

May be covered at the discretion of the Medicare Administrative Contractor. Commercial plan coverage may vary

COVID Specim en Collect ion

Nasal swab specimen collection for COVID testing will no longer be eligible for separate reimbursement. While reporting HCPCSC9803 (HOSPITAL OUTPATIENT CLINICVISIT SPECIMEN COLLECTION FORSEVEREACUTERESPIRATORYSYNDROMECORONAVIRUS2 (SARS-COV-2) (CORONAVIRUSDISEASE[COVID-19]), ANYSPECIMEN SOURCE) is not expected to cause claim rejections, it will not be reimbursed after 5/11/2023.

Out pat ient COVID Treat m ent w it h Veklury (rem desivir)

Will continue to be covered, but the cost will carry patient liability for the usual Medicare deductible and coinsurance Commercial plan coverage may vary (There are currently no COVID-19 monoclonal antibodies approved or authorized for use against the dominant strains of COVID-19 in the United States.)

FACILITY BILLINGAFTERTHEPHE

Modifier CS

Will no longer relieve patients of financial liability for evaluation and management charges when a practitioner orders a COVID test after 5/11/2023; patients will be responsible for the ordinary deductible and coinsurance obligations for problem-focused evaluation and management services.

Telem edicine

Delivered by billing professionals (not facilities) will continue to be an option for Medicare beneficiaries subject to Medicare?s ?List of Telehealth Services for Calendar Year 2023 " Professional fees for telehealth services will continue to be paid at the non-facility rate under the Medicare Physician Fee Schedule However, telehealth equipment must be HIPAA compliant after 5/11/2023

HCPCS Q3014

(Telehealth originating facility fee) should no longer be reported on a facility fee claim for supporting a facility-based physician or non-physician practitioner performing a telemedicine service Hospitals may report Q3014 only if the patient comes to the facility to utilize HIPAA-compliant telehealth equipment while a distant site practitioner performs a telemedicine visit.

Telem edicine Equipm ent

During the PHE, HHSissued a temporary notice to allow covered providers to use popular non-public facing communications apps to deliver telehealth during the COVID-19 PHE, such as Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, Zoom, and Skype After 5/11/2023, telehealth equipment must utilize HIPAA-secure technology, and a Business Associates Agreement must be in place with the technology provider.

Rem ot e Services Provided By Facilit ies

Will no longer be covered by Medicare (except certain mental health or substance abuse disorder treatment reported with HCPCSC7900 ? C7902 ) Some facilities took advantage of a PHEwaiver which allowed the hospital to bill for certain therapies (such as physical, occupational, speech, medical nutrition, or diabetes self-management training) over remote communications technology to patients in the home setting. This flexibility ends on May 11, 2023. (Although physical and occupational therapistsin privatepracticemayoffer servicesvia telehealth after the PHEends, hospitalswill no longer bepermitted to bill for remotefacility servicesdelivered via communicationstechnology.)

Skilled Nursing/ Sw ing Bed Coverage

Medicare?s waiver of the 3-day qualifying inpatient stay as a prerequisite for Medicare coverage of a Skilled Nursing Facility or Swing Bed care will end; coverage of skilled care/swing bed stays will again require the pre-qualifying 3-day stay All new SNFstays beginning on or after 5/12/2023 will require a qualifying hospital stay before Medicare coverage.

Enhanced DRG Paym ent s

The CARESAct provided a 20% add-on payment to IPPSDRG reimbursement for treating COVID-19 inpatients (ICD-10 diagnosis codes U07 1 or B97 27) will end for inpatients discharged after May 11, 2023. However, the new COVID-19 treatments add-on payments (NCTAP), which increase payment when specific treatments such as convalescent plasma and remdesivir are reported within the ICD-10 codes on an inpatient claim, will continue through September 30, 2023.

COVID Vaccines

Will continue to be covered in full without cost by Medicare. Medicare Advantage members and commercial health plans subject to the Affordable Care Act will continue to cover COVID vaccinations without cost, provided that the beneficiary receives care at an in-network provider. Check with the individual plan for details of coverage.

Hom e COVID Test s

Medicare beneficiaries will no longer be entitled to receive 8 home COVID tests per month per household Commercial plan coverage may vary

For more information, please visit Medicare?s FAQ document at: https://www cms gov/files/document/frequently-asked-questions-cms-waivers-flexibilitiesand -end-covid-19-public-health-emergency.pdf

CONSIDERATIONS

Palliative Care Coverage

And Considerations

Background

Many community hospitals are responding to the needs of their patients by offering palliative care programs Typically, a Nurse Practitioner is employed to provide services which ease the condition of patients and their families enduring distressing, painful medical conditions.

Typically, a nurse practitioner providing palliative care will report a problem-focused Evaluation and Management code to report professional fees, with an ICD-10 code and documentation which supports medical necessity The difference between palliative care and hospice care is described in the following Medicare document:

Palliative Care vs Hospice Care Similar but Different (cms gov)

PALLIATIVECARECOVERAGEAND CONSIDERATIONS

Frequent ly Asked Quest ions

1 The person hired t o do t he Palliat ive Care is a Nurse Pract it ioner Is t hat is a billable service?

Answ er: Services of a Nurse Practitioner are billable as professional fees, provided of course that the services billed are medically necessary and the nurse practitioner is properly enrolled with the payer.

2. Our Nurse Pract it ioner w ill be seeing bot h inpat ient s and out pat ient s in t he hospit al She m ay also be seeing pat ient s in t heir hom es

Be sure the NPis enrolled with Medicare and included under your medical group NPI with an 855B form (or on PECOS) no more than 30 days prior to the date on which the NPwill begin seeing patients.

The NPmust also update the NP?s individual Medicare enrollment (855I/PECOS) to add locations of service which include the facility and patient home visits. NPservices billed as professional fees will be reimbursed at 85%of the Medicare physician fee schedule (CAH Method II note: nurse practitioner services in the outpatient hospital setting must be billed with modifier -GFappended to the CPT® code on the UB/837i.)

Verify that the appropriate E/M codes are available with in the chargemaster, and ensure that the appropriate Place of Service codes are also reportable Typical professional fee codes would include, but not be limited to the following:

Out pat ient visit s in the clinic or hospital setting: 99202- 99215

Inpat ient s ? 99221- 99223

Hom e or dom iciliary visit s ? 99341- 99350

Typical Place of Service codes:

21 ? Hospit al Inpat ient

22 ? Hospit al Out pat ient

12 - Hom e

13 ? Assist ed Living Facilit y

3 Are t here any guidelines for Palliat ive Care program s?

Answ er: The National Coalition for Hospice and Palliative Care offers a guideline at the link here: https://www nationalcoalitionhpc org/ncp/

PALLIATIVECARECOVERAGEAND CONSIDERATIONS

The Center to Advance Palliative Care offers a variety of resources on palliative care: https://www capc org/

Medicare Coverage and Medical Necessit y

Palliative care is covered by Medicare if the service is medically necessary Here?s an excerpt from the Medicare Benefits Policy Manual, Chapter 16 - General Exclusions From Coverage: https://www cms gov/Regulations-andGuidance/Guidance/Manuals/Downloads/ bp102c16 pdf#

PALLIATIVECARECOVERAGEAND CONSIDERATIONS

The Medicare Benefit Policy Manual describes coverage for the services of Nurse Practitioners in Chapter 15 ? Covered Medical and Other Health Services: http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/Downloads/bp102c15.pdf

200 - Nurse Pract it ioner (NP) Services (Rev. 11771 ; Issued:12-30-22 ; Effective:01-01-23 ; Implementation:01-01-23 ) ?

B Coverage is limited to the services an NPis legally authorized to perform in accordance with State law (or State regulatory mechanism established by State law)

2 Services Otherwise Excluded From Coverage The NPservices may not be covered if they are otherwise excluded from coverage even though an NPmay be authorized by State law to perform them For example, the Medicare law excludes from coverage routine foot care, routine physical checkups, and services that are not reasonable and necessary for the diagnosis or treatment of an illness or injury or to improve the functioning of a malformed body member Therefore, these services are precluded from coverage even though they may be within an NP?s scope of practice under State law ?

Advance Care Planning

In 2015, AMA created two new CPT® codes (99497 and 99498) for counseling patients on advance care planning, which is frequently a component of palliative care Medicare covers these services for both professionals and facilities:

99497 - Advance care planning including the explanation and discussion of advance directives such as standard forms (with completion of such forms, when performed), by the physician or other qualified health care professional; first 30 minutes, face-toface with the patient, family member(s), and/or surrogate

99498 - Advance care planning including the explanation and discussion of advance directives such as standard forms (with completion of such forms, when performed), by the physician or other qualified health care professional; each additional 30 minutes (list separately in addition to code for primary procedure)

Medicare reimbursement rates are available in the PARA Data Editor:

Care Managem ent Program s

Medicare also covers several different types of care management programs to assist providers in meeting the needs of seriously ill Medicare beneficiaries. A link and a screenshot of the Medicare website that summarizes those programs is provided below: https://www cms gov/Medicare/Medicare-Fee-for-ServicePayment/ PhysicianFeeSched/Care-Management

Click On The Document Below For An Important Notice

FDA Simplifies COVID-19 Vaccines

On April 18, 2023, the FDA authorized an amendment to the Emergency Use Authorization (EUA) for COVID-19 bivalent vaccines for all patients ages 6 months and older. Monovalent COVID-19 vaccines offered through Pfizer-BioNTech and Moderna are no longer authorized in the United States

Coronavirus (COVID-19) Update: FDA Authorizes Changes to Simplify Use of Bivalent mRNACOVID-19 Vaccines

The amended EUA provides the following information:

- Patients who had a monovalent COVID-19 vaccine only may receive one bivalent vaccine

- Unvaccinated patients may receive one bivalent vaccine

- Most patients who have already had one dose of bivalent are considered fully vaccinated at this time. The FDA may revise this decision after the FDA Advisory Committee meeting in June

Exceptions to this include:

- Patients aged 65 or older ? may receive an additional bivalent vaccine at least four months following the first

- Patients with immunocompromised conditions ? may receive an additional bivalent vaccine at least two months following the first with additional doses as determined by the healthcare provider The FDA states there are additional considerations for patients aged 6 months ? 4 years

The FDA offers additional recommendations for children ages 6 months through 5 years depending upon previous COVID-19 vaccination administrations

CorroHealt h invit es you t o check out t he m lnconnect s page available from t he Cent ers For Medicare and Medicaid (CMS). It 's chock full of new s and inform at ion, t raining opport unit ies, event s and m ore! Each w eek PARA w ill bring you t he lat est new s and links t o available resources. Click each link for t he PDF!

Thursday, May 4, 2023

New s

- FAQs on CMSWaivers, Flexibilities, and the End of the COVID-19 Public Health Emergency

- Guidance for the Expiration of the COVID-19 Public Health Emergency

- COVID-19 Over-the-Counter Tests

- Medicare Diabetes Prevention Program: Public Health Emergency Flexibilities Continue through December 31

- Transplant Eco-System: Role of Data in CMSOversight of The Organ Procurement Organizations

- Expanded Home Health Value-Based Purchasing Model: April Newsletter & Performance Reports

- Religious Nonmedical Health Care Institution Benefit & COVID-19 Vaccines

- Clinical Laboratory Fee Schedule 2024 Preliminary Gapfill Rates: Submit Comments by June 26

- Mental Health: Recommend Medicare Preventive Services

Claim s, Pricers, & Codes

- COVID-19: Reporting CRModifier & DRCondition Code After Public Health Emergency Update

- Claim Status Category & Claim Status Codes

Event s

t r ans mit t al s

Therew ereEIGHT new or revised Transmittalsreleased thisw eek.

To go to thefull Transmittal document simply click on thescreen shot or thelink.

TRANSMITTAL R12015OTN

TRANSMITTAL R12017OTN

TRANSMITTAL R12021CP

TRANSMITTAL R12019OTN

TRANSMITTAL R12022OTN

TRANSMITTAL R12023CP

TRANSMITTAL R11997MSP

1 m edl ear ns

Therew as1new or revised MedLearnsreleased thisw eek.

To go to thefull Transmittal document simply click on thescreen shot or thelink.

Theprecedingmaterialsare for instructional purposesonly. Theinformation ispresented "as-is"and to thebest of CorroHealth'sknowledgeisaccurateat thetimeof distribution. However, due to the ever-changinglegal/regulatory landscape, thisinformation issubject to modification asstatutes, laws, regulations, and/or other updatesbecome available. Nothingherein constitutes, isintended to constitute, or should berelied on aslegal advice. CorroHealth expresslydisclaimsanyresponsibilityfor anydirect or consequential damagesrelated in anywayto anything contained in thematerials, which areprovided on an "as-is"basisand should beindependentlyverified before beingapplied. You expresslyaccept and agree to thisabsoluteand unqualified disclaimer of liability. The information in thisdocument isconfidential and proprietaryto CorroHealth and isintended onlyfor thenamed recipient. No part of thisdocument maybereproduced or distributed without expresspermission. Permission to reproduceor transmit in anyform or byanymeanselectronicor mechanical, includingpresenting, photocopying, recording, and broadcasting, or byanyinformation storageand retrieval system must beobtained in writingfrom CorroHealth. Request for permission should bedirected to Info@Corrohealth.com.