Do you have questions, comments, suggestions about Covid-19 billing, compliance, policies & more? 
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February 25, 2022 CDC eases mask guidance for 70% of US including schools
Under the new guidelines, more than 70 percent of the U.S. population is in an area with “low” or “medium” COVID-19 community level, meaning masks are not recommended for the general public.  Check your State & County HERE

January 13, 2022 SCOTUS ok's CMS mandate and overrules OSHA mandate

Many SNFs and healthcare providers expressed concerns with staffing shortage crisis. 

January 9, 2022 5 States require Covid 19 booster for Nursing Home Staff

Amid the latest COVID-19 surge, Massachusetts, New York and Connecticut became the latest states this week to require health care workers, including nursing home staff – to get a booster shot. They join California and New Mexico, bringing the total number so far to five.

November 30, 2021 Judge halts Biden's Covid Vaccine Mandate for healthcare workers Nationwide
Louisiana-based federal Judge Terry Doughty issued a preliminary injunction Tuesday evening, prohibiting the Centers for Medicare and Medicaid Services from enforcing its healthcare worker vaccine mandate. The injunction applies to 40 U.S. states — in a separate ruling Monday, a federal judge in Missouri temporarily blocked the CMS vaccine mandate in the other 10 states.
Q: Is this ban temporary? 
A: This is a preliminary injunction
Read More

November 4, 2021 Regulation Requiring Covid 19 Vaccinations for Healthcare workers takes affect
Q: Are any regulated provider or supplier types excluded?

A: PXR Providers are exempt but are indirectly required to comply with this regulation....Read more. Religious Nonmedical Health Care Institutions (RNHCIs), Organ Procurement Organizations (OPOs), and Portable X-Ray Suppliers are not included in these requirements. 3 RNHCIs do not furnish, on the basis of religious beliefs, through its personnel or otherwise, medical items and services (including any medical screening, examination, diagnosis, prognosis, treatment, or the administration of drugs) for their patients, but instead furnish only nonmedical nursing items and services to beneficiaries who choose to rely solely upon a religious method of healing, and for whom the acceptance of medical services would be inconsistent with their religious beliefs (Note that the religious components of this type of healing services are not covered by CMS under this benefit; only nonmedical items and services provided exclusively through nonmedical nursing personnel who are experienced in caring for the physical needs of nonmedical patients are covered). We therefore do not believe it would be appropriate to CMS For OPOs and Portable X-Ray Suppliers, it is important to note that the staff of these entities are indirectly included in the vaccination requirements through their service arrangements with hospitals, LTC facilities, and other providers and suppliers included under this rule. A service arrangement is when these providers have a contract with other providers to furnish services. That contract may require individuals from these organizations to be vaccinated. Additionally, it is possible that entities not covered by this rule may still be subject to the other state or federal COVID-19 vaccination requirements, such as those being issued by the Occupational Safety and Health Administration (OSHA) Read More

Q What about religous/medical employee exemptions? How do I handle these exemptions?
A. APDA has provided the following publications that may help you:


September 3, 2021 HRSA releases fact sheet on Provider Relief Fund uses related to personnel costs


Q. 6/10/20 My employee tested positive for Covid 19, what is the reporting process?
A. Contact your local department of health. The CDC has information on the reporting process for Health Departments along with the form that the Health Department uses to collect data. Your local Health Department is responsible for assisting you with the tracing process. 

Q. 5/20/20 Is there a publicly available list of providers and the payments they received through the Provider Relief Fund? 
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”? 
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:

Q. What is the employee retention credit and how do I know if my business qualifies?
A.  Per "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:
  • Have operations that were fully or partially suspended during any calendar quarter in 2020 due to orders from an appropriate governmental authority limiting commerce, travel, or group meetings (for commercial, social, religious, or other purposes) due to COVID-19; or
  • Experienced a significant decline in gross receipts during the calendar quarter.
Q. How often do Nursing homes have to assure testing of staff and vendors? 
  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: and this link for official CMS memorandum:

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? 
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

Q, Can I use Covid-19 exposure ICD10 codes for all patients that are in a risk category but not tested or suspected?
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:

Q. Is it true that if we have a PPP loan under $2M it will be eligible for foregiveness?
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:

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:

Reporting Period 2 Is Open

Providers who are required to report in Reporting Period 2:

  • The PRF Reporting Portal opened for Reporting Period 2 on January 1, 2022 and will remain open through March 31, 2022 at 11:59 PM ET.
  • Providers who received one or more General and/or Targeted PRF payments exceeding $10,000, in the aggregate, from July 1, 2020 to December 31, 2020 must report on their use of funds in Reporting Period 2.
  • The deadline to use funds for Payment Received Period 2 was December 31, 2021.

Upcoming reporting periods:

  • Reporting Period 3 opens on July 1, 2022
  • Reporting Period 4 opens on January 1, 2023

Accelerated and Advanced Re-Payment Reminder
In October 2020, CMS announced amended terms for payments issued under the AAP program to extend repayment to start one year after the loan payment. As many of the initial loans started in April 2020, the first 11 months of repayment ended February 2022. Providers with an outstanding loan balance should prepare for recoupments to increase from 25% to 50% starting March 2022.
Please review our article, Learn about CMS' amended repayment process for accelerated and advance repayments for details on the repayment terms and access helpful FAQs.