Do you have questions, comments, suggestions about Covid-19 billing, compliance, policies & more?
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Q. 5/20/20 Is there a publicly available list of providers and the payments they received through the Provider Relief Fund?
A. As per CMS Cares Act FAQ ...."HHS has posted a public list of providers and their payments once they attest to receiving the money and agree to the Terms and Conditions. All providers that received a payment from the Provider Relief Fund and retain that payment for at least 45 days if received via ACH or 60 days from check issuance without rejecting the funds are deemed to have accepted the Terms and Conditions. Providers that affirmatively attest through the provider portal or that retain the funds past 45 days of receipt of payment via ACH or within 60 days of check payment issuance, but do not attest will be included in the public release of providers and payments. The list includes current total amounts attested to by providers from each of the Provider Relief Fund distributions, including the General Distribution, Rural Distribution, and High-Impact Areas Distribution. The list is available here.
Q. 5/6/20 Do the Terms and Conditions for the General, Rural or High Impact Distributions require attesting to a ban on balance billing for all patients and/or all care, because “HHS broadly views every patient as a possible case of COVID-19”?
A. As per CMS Cares Act FAQ dated 5/6/20... "No. As set forth in the Terms and Conditions, the prohibition on balance billing applies to “all care for a presumptive or actual case of COVID-19.” " see link: https://www.hhs.gov/sites/default/files/provider-relief-fund-general-distribution-faqs.pdf
Q. What is the employee retention credit and how do I know if my business qualifies?
A. Per IRS.gov: "The Employee Retention Credit under the CARES Act encourages businesses to keep employees on their payroll. The refundable tax credit is 50% of up to $10,000 in wages paid by an eligible employer whose business has been financially impacted by COVID-19. Eligible Employers that are entitled to claim the Employee Retention Credit are private-sector businesses and tax-exempt organizations that carry on a trade or business during calendar year 2020 and either:
A. According to CMS nursing home reopening recommendations and as of May 18, 2020 -"all nursing home staff should receive a baseline test and continue to be tested weekly. Per CMS memorandum: The facility should have a written testing plan in place.....Written screening protocols for all staff (each shift), each resident (daily), and all persons entering the facility, such as vendors, volunteers, and visitors. At minimum, the plan should have....The capacity for all nursing home staff (including volunteers and vendors who are in the facility on a weekly basis) to receive a single baseline COVID-19 test, with re-testing of all staff continuing every week (note: State and local leaders may adjust the requirement for weekly testing of staff based on data about the circulation of the virus in their community)." All pxr providers should check with their local Department of health for continued requirements along with their nursing home for specific requirements. See this FAQ link: https://www.cms.gov/files/document/covid-nursing-home-reopening-recommendation-faqs.pdf and this link for official CMS memorandum: https://www.cms.gov/files/document/nursing-home-reopening-recommendations-state-and-local-officials.pdf
Q. Many blanket waivers do not seem to apply to portable x-ray or IDTF, where can I get more information? Can I apply for a waiver?
A. See the following link for an explanation of waivers and how they work. If you have a need that is not already covered under the blanket waiver, you may request for a waiver. See this link for more information: https://www.cms.gov/files/document/cms-waivers-and-covid-19-response.pdf
Q, Can I use Covid-19 exposure ICD10 codes for all patients that are in a risk category but not tested or suspected?
A. Documentation in each patient's medical record and the exam order must support the exposure event and the medical necessity for the exam itself as it is related to the exposure. As noted in CDC April 1, 2020 Guidelines - "Exposure to COVID-19 For cases where there is a concern about a possible exposure to COVID-19, but this is ruled out after evaluation, assign code Z03.818,..... For cases where there is an actual exposure to someone who is confirmed or suspected (not ruled out) to have COVID-19, and the exposed individual either tests negative or the test results are unknown, assign code Z20.828, Contact with and (suspected) exposure to other viral communicable diseases."
Q. Does modifier CS (Cost Sharing) apply to portable x-ray or ultrasound services?
A. The Families First Coronavirus Response Act waives cost-sharing under Medicare Part B (coinsurance and deductible amounts) for Medicare patients for COVID-19 testing-related services. These services are medical visits for the HCPCS evaluation and management categories described below when an outpatient provider, physician, or other providers and suppliers that bill Medicare for Part B services orders or administers COVID-19 lab test U0001, U0002, or 87635. At this time portable x-ray and ultrasound services are not considered approved testing as related to the CS modifier. see further explanation: https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-07-mlnc-se#_Toc37139913
Q. Is it true that if we have a PPP loan under $2M it will be eligible for foregiveness?
A. The SBA in consultation with the Department of Treasury has determined......"Any borrower that, together with its affiliates, received PPP loans with an original principal amount of less than $2 million will be deemed to have made the required certification concerning the necessity of the loan request in good faith." see further explanation: https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequently-Asked-Questions.pdf
Q. May 13, 2020 Does the new $15 Million support for telehealth providers during Covid-19 pandemic apply to portable X-ray?
A. At this time Portable X-ray is not considered within the service definition of telehealth. See further explanation: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/TelehealthSrvcsfctsht.pdf