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Medicare Compliance & Reimbursement

Covid-19 Round-Up:

Maximize Your COVID Resources With These Timely Updates

Published on Mon Jul 04, 2022

Tip: Check with your MAC on PHE-related policies.

As the pandemic stretches on and cases ebb and flow with each new variant, COVID-19 policymaking continues to evolve. Read on for some new updates that may impact your Medicare compliance and reimbursement.

Expect the PHE to Get Another Extension

HHS Secretary Xavier Becerra renewed the public health emergency (PHE) on April 16, 2022, and it is in effect until July 15, 2022. Find the PHE declaration at https://aspr.hhs.gov/legal/PHE/Pages/COVID19-12Apr2022.aspx.

Even though the PHE is slated to end on July 15, experts believe there’s a good chance the PHE will be extended again.

Why? President Biden said that states would get 60 days’ notice before the PHE would be declared over, and at press time, his administration had not mentioned any changes to his previous statements. However, some federal agencies have started to pause or end waivers related to COVID-19 and are reverting to pre-PHE requirements (see Medicare Compliance & Reimbursement, Vol. 48, No. 8).

That’s why it’s critical that you make sure you’re staying on top of those changes and checking with your Medicare Administrative Contractor (MAC) for any jurisdictional updates.

CMS Offers Fresh Guidance on COVID Vax Mandates

If your practice is struggling with maintaining compliance with Medicare’s COVID-19 vaccination rules for staff, then the recent oversight changes may lighten your load.

“Survey oversight of the staff vaccination requirement for Medicare and Medicaid-certified providers and suppliers will continue to be performed during initial and recertification surveys, but will now only be performed in response to complaints alleging non-compliance with this requirement, not all surveys,” the Centers for Medicare & Medicaid Services says in a new survey memo issued June 14. “Under prior guidance, all surveys included oversight of the staff vaccination requirement,” CMS points out in QSO-22-17-ALL.

Since February, “nearly 12,000 providers and suppliers have been surveyed for compliance with the requirement,” CMS points out. “To date, 95.0% of those providers and suppliers surveyed by states have been found to be in substantial compliance with this requirement.”

Details: “State Survey Agencies should reach out to their CMS Location if they are considering citing vaccine requirements at immediate jeopardy, Condition or actual harm levels,” the memo instructs. CMS is updating the interpretive guidance “to ensure that deficiency citations recognize good faith efforts by providers/suppliers and to more fully evaluate harm or potential harm to patients/residents by considering trends in COVID-19 rates in the community,” CMS says.

The memo is at www.cms.gov/files/document/qso-22- 17-all.pdf.

OIG Adds COVID-Related Audits to the Work Plan

The nation’s healthcare watchdog, the HHS Office of Inspector General (OIG), continues to update the Work Plan with PHE-related items.

Tests: Medicare Part B providers should get ready for extra scrutiny of their add-on payments for COVID-19 tests, OIG’s Work Plan active item W-00-22-35884 suggests.

“On October 15, 2020, CMS announced actions to incentivize prompt COVID-19 test turnaround times by paying more for expedited results. CMS has identified that timelier test results benefit individual patients, their immediate communities, and the public at large,” OIG reminds.

According to the Work Plan, CMS reduced the base payment for COVID-19 clinical diagnostic laboratory tests (CDLTs) that use high-throughput technology in 2021, but at the same time, attached a $25 add-on payment for the tests. Now, the agency wants to review Part B providers’ notes to ensure they were following the rules and not gaming the system.

“For this audit, we will review providers’ supporting documentation for the COVID-19 CDLT add-on payments to determine whether the documentation complied with Medicare requirements,” OIG says.

Find the active item at https://oig.hhs.gov/reports-and-publications/workplan/summary/wp-summary-0000706.asp.

PRF Reporting Period 3 Is Now Open

If you received more than $10,000 in HHS Provider Relief Fund (PRF) payments for either the General or Targeted distributions between Jan. 1, 2021 and June 30, 2021 — and used those funds for your practice — it’s time to attest for Reporting Period 3 (RP3). And remember, all payments from RP3 must have been used by the June 30, 2022 deadline.

“Providers who accepted PRF payment(s) agreed to the Terms and Conditions of the program which included a requirement to report on the use of the funds,” notes HHS Health Resources & Services Administration (HRSA) in online guidance. “Reporting is an important process in understanding how the program had an impact nationwide. Providers who do not submit a completed report are considered non-compliant with the Terms and Conditions,” HRSA warns.

The PRF portal for RP3 opened on July 1 and will run through Sept. 30, 2022.

Review the particulars with a link to attest at www.hrsa.gov/ provider-relief/reporting-auditing.

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