As our country navigates the COVID-19 pandemic, questions continually arise regarding sweeping changes to our healthcare system. The experts at Advis have compiled a list of pressing FAQs and their answers to assist organizations at the center of the crisis. Advis remains committed to staying on top of all regulatory updates and communicating what they mean for our nation’s healthcare providers. Advis stands ready to provide answers. From FEMA and telehealth funding to coding and documentation, our team has the knowledge and the experience to guide providers through these unprecedented times.
Question: Will CMS reimburse hospitals for telehealth therapy services provided by hospital-based physical therapists and occupational therapists?
Answer: As of April 14, 2020, CMS will not reimburse hospitals for telehealth services provided by hospital-based PTs and OTs. However, on provider conference calls CMS has indicated that such reimbursements will likely be available and that the effective date may be retroactive.
Question: What type of labor costs will FEMA reimburse?
Answer: Absent additional guidance, FEMA will most likely only reimburse overtime for budgeted employees, and straight- and overtime pay for non-budgeted employees. FEMA will not likely reimburse salary costs/labor time for any exempt employees, but it may provide reimbursement for bonuses paid pursuant to pre-existing labor policies. All labor reimbursed by FEMA must be directly related to an eligible emergency protective measure. Additionally, Advis recommends tracking all labor time (exempt and hourly) if it directly relates to COVID-19 activities to best prepare for any reimbursement/funding that may be provided under the CARES Act.
Question: How does private fund raising / donations impact our FEMA eligible expenses? Should we slow down fundraising?
Answer: Private funding can impact FEMA reimbursement. However, we do not recommend slowing down fundraising (cash in hand is better than POSSIBLE FEMA funds). What we do recommend is taking pro-active steps to mitigate any negative impact. To the extent possible, fundraising should not dedicate funds to specific projects that may be FEMA eligible. For example, make donations to “COVID-19 Relief” not “COVID-19 PPE”, as the more specific designation is more likely to impact possible FEMA reimbursement for PPE.
Per FEMA’s detailed guidelines, grants and cash donations from non-Federal sources are subject to the following criteria:
- If the funds are designated for the same purpose as eligible work, the following apply:
o The Applicant may use the funds toward its non-Federal cost share.
o If the funds are not used toward the non-Federal cost share, FEMA considers the donation or non-Federal grant a duplication of benefits and reduces eligible costs by the duplicated amount.
o If the funds exceed the amount of the non-Federal cost share, FEMA reduces eligible costs by the excess amount.
- If the funds are designated for non-specific purposes, FEMA does not consider the funds a duplication of benefits. The Applicant may use the funds toward its non-Federal cost share. If the funds exceed the amount of the non-Federal share, the Applicant can apply the excess amount toward ineligible work.
- If the funds are designated for a specific purpose that is not eligible, FEMA does not allow the Applicant to apply the funds toward its non-Federal cost share
Question: When will the remaining CARES Act funding ($70B) be disbursed to healthcare providers?
Answer: The date has not been set definitively, but increasingly it looks like the funds may be disbursed as early as this Friday and probably no later than next week. In addition, it appears at least some portion of the funds, if not all of it, will be application based. Therefore, providers should continue their readiness efforts and continue to track lost revenue, direct and indirect costs, charity care, and other applicable reimbursable items.
Question: When submitting expense reports for the CARES Act Provider Relief Fund, which costs should we prioritize?
Answer: Providers that have received funding from the CARES Act Provider Relief Fund should prioritize covering costs associated with lost revenue and patient care for uninsured COVID-19 patients requiring long-term care (e.g. inpatient stays), as these costs are not recoverable under other funding sources such as FEMA.
Question: Am I eligible for the FCC $200 million Telehealth Funding opportunity?
Answer: The following providers are eligible for funding under the FCC opportunity: (1) post-secondary educational institutions offering health care instruction, teaching hospitals, and medical schools; (2) community health centers or health centers providing health care to migrants; (3) local health departments or agencies; (4) community mental health centers; (5) not-for-profit hospitals; (6) rural health clinics; (7) skilled nursing facilities; or (8) consortia of health care providers consisting of one or more entities falling into the first seven categories.
Question: Does Advis have any guidance on how we are to document and code COVID-19 patients in order to receive the Medicare 20% Add-on?
Answer: During the emergency period, the Medicare IPPS Add-on payment for COVID-19 patients is an automatic 20 percent increase to the weighing factor for discharges of Medicare patients with a COVID-19 diagnosis.
Hospitals should continue using the applicable condition ICD-1)-CM coding guidance.
Question: Can a for-profit organization apply for FEMA assistance funds?
Answer: At this time, FEMA is only providing assistance funds to private not-for-profit organizations.
Question: How should a physician bill for a telehealth visit done with the patient and physician in the same location, but separate rooms? The patient is in a room with a laptop and the doctor uses the laptop to communicate with the patient for the visit rather than going into the room with the patient?
Answer: CMS has stated that when the provider and patient are within the same location, it is not considered telehealth. Thus, when a provider uses technology to provide a visit to a patient located in the same physical location as the provider, the provider can bill the usual code for the visit rather than applying a telehealth code.
Question: Our hospital is opening new space to treat COVID-19 patients that is separate from existing hospital locations. Can the hospital still compliantly dispense 340B drugs at these new locations?
Answer: Yes, provided HRSA provides approval. HRSA is granting immediate 340B eligibility for new COVID-19 facilities on a case by case basis. Covered Entities are instructed to reach out to Apexus via email phone (1-888-340-2787) to make such requests. Covered Entities should be prepared to detail the need for immediate registration of the facility to support the hospital’s COVID-19 response and otherwise demonstrate its ability to meet other 340B program requirements at that facility. Please note that requests can be made outside of HRSA’s normal 340B quarterly enrollment periods.
For more information, or to get in touch with the experts at Advis contact us online or call 708-478-7030
Published: April 16, 2020