HFMA recommended coronavirus resources

The list below includes links to resources HFMA’s members will find useful as they help navigate their organizations through the COVID-19 emergency. These resources include information related to Medicare, state, and commercial health plans.

These resources include links to the best currently available information related to coding, billing, coverage of services, and disaster preparedness financing during the COVID-19 national emergency.

COVID-19 Billing & Coding

• New voluntary billing guidance available for COVID-19 alternate site care delivery: HFMA partnered with America’s Health Insurance Plans to provide clear, useful voluntary guidance for providers to code, bill and seek payment for services rendered in temporary, alternate healthcare sites that may be used during the COVID-19 public health emergency. Guidance is available for outpatient and inpatient sites.
• CDC COVID-19 ICD-10 Coding and Reporting Guidelines: The CDC’s most current guidelines are available by clicking the link in the title.
• AMA Coding Scenarios: The AMA created a document outlining their recommendations for coding COVID-19 cases under a range of different scenarios. 
• AAPC COVID-19 Coding Guidelines: AAPC has done a nice job of keeping this updated as new codes are released. 
• COVID-19 Vaccine Codes and PC-ACE Software Update: In anticipation of the availability of a vaccine(s), for the novel coronavirus (SARS-CoV-2) in response to the coronavirus disease 2019 (COVID-19), the American Medical Association (AMA), working with the Centers for Medicare & Medicaid Services (CMS), created new codes for the vaccine and the administration of the vaccine.  To prepare for the vaccine administration claims, the PC-ACE software is also updated and ready for providers to download.

  If you intend to administer the COVID-19 vaccines when they become available, or the new monoclonal antibody bamlanivimab, especially if you intend to roster bill these codes, please download and install the new release of PC-ACE. This release includes the coding structure, currently comprised of both a HCPCS Level I CPT code structure issued by the American Medical Association (AMA) and a HCPCS Level II code structure issued by CMS. Together, these codes support the administration of the COVID-19 vaccines and the monoclonal antibody infusions, as they become available; this structure includes the codes for bamlanivimab. This code structure was developed to facilitate efficient claims processing for any COVID-19 vaccines and monoclonal antibody infusions that receive FDA EUA or approval. CMS and the AMA are working collaboratively regarding which codes to submit for COVID-19 vaccines and administration.  Most of these codes are not currently effective and not all codes will be used.  We will issue specific code descriptors in the future.  Effective dates for the codes for Medicare purposes will coincide with the date of the FDA EUA or approval.

Data Reporting:

• COVID-19 Data Reporting to HHS: Hospitals will begin sending coronavirus-related information directly to the Department of Health and Human Services (HHS), not the Centers for Disease Control and Prevention (CDC), under new instructions from the Trump administration.

CARES Act Uninsured COVID-19 Coverage

• COVID-19 Uninsured Coverage General Information: As part of the FFCRA and CARES Act, the U.S. Department of Health and Human Services (HHS), will provide claims reimbursement to health care providers generally at Medicare rates for testing uninsured individuals for COVID-19 and treating uninsured individuals with a COVID-19 diagnosis. Providers who enroll may begin submitting claims, which will be paid on a first come, first serve basis, on May 6^th. FAQs are available here. 

CARES Act Relief Funding

• Distribution of the Remaining Initial Appropriation of CARES Act Provider Relief Funding: HHS continues to distribute appropriated funds to providers. This link provides up-to-date information on the amounts allocated to the various provider types and the methodologies used to distribute those funds.
• General Distribution FAQs: Provides FAQs on terms and conditions and data required by HHS to support payments from the CARES Act Provider Relief Fund.  
• HRSA Provider Relief Fund – General Allocation Distribution Data: HHS has released a data base of payments from the CARES ACT General Distribution.  Each row is a provider (aligned with billing TIN) who has received at least one payment which they have attested. If a provider received 2 payments and attested to both, both payments are included. If a provider received 2 payments and only attested to 1 payment, only the attested payment is included. While the detail is lacking, the file can be used to make sure you’ve received all of the payments they’ve sent.
• General Distribution Portal:  HHS has opened the General Distribution Portal for providers without adequate cost report data on file to submit their net revenue information for an additional distribution from the CARES Act Relief Fund’s $50B General Allocation. Providers who received their money automatically will still need to submit their revenue information to the portal so that it can be verified.
• Uninsured COVID-19 Patients: Every health care provider who has provided treatment for uninsured COVID-19 patients on or after February 4, 2020, can request claims reimbursement through the program and will be reimbursed at Medicare rates, subject to available funding. Steps will involve: enrolling as a provider participant, checking patient eligibility and benefits, submitting patient information, submitting claims, and receiving payment via direct deposit. Providers can register for the program on April 27, 2020, and begin submitting claims in early May 2020.
• Provider Attestation Portal: HHS has opened the CARES Act Provider Relief Fund Payment Attestation Portal.  Providers who received funding from the CARES Act Relief fund will need to use this to attest to complying with the terms and conditions of the funding.

COVID-19 Legislation

• Small Business Administration Clarifies that Governmental Hospitals for Small Business Administration Loans: On Friday, the SBA issued an interim final rule clarifying that 501(c)(3) hospital shall not be rendered ineligible for a PPP loan due to ownership by a state or local government if the hospital receives less than 50% of its funding from state or local government sources, exclusive of Medicaid.
• 20% COVID-19 Payment Increase for Medicare MS-DRGs: CMS, in the April 15, 2020, MLN Connects Newsletter announced it is implementing changes to increase payments to IPPS hospitals and LTCHs under Sections 3710 and 3711 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. When a hospital submits an IPPS claim for discharges on or after January 27, 2020, or an LTCH claim for admissions on or after January 27, 2020, and CMS receives it:
  • April 20, 2020, and earlier, Medicare will reprocess. You do not need to take any action.
  • On or after April 21, 2020, Medicare will process in accordance with the CARES Act.
• FAQ on COVID-19 Cost Sharing for Testing and Related Services: On April 11, 2020 the Departments of Health and Human Services, Labor, and Internal Revenue Service (hereafter the “Tri-Agencies”) issued an FAQ related to clarify the implementation of provisions in the Families First Coronavirus Response Act (the FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) requiring health plans to cover COVID-19 testing and related services.
• FAQ on COVID-19 Cost Sharing for Testing and Related Services:  On June 23, 2020 the Departments of Health and Human Services, Labor, and Internal Revenue Service (hereafter the “Tri-Agencies”) issued answers to additional FAQs related to clarify the implementation of provisions in the Families First Coronavirus Response Act (the FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) requiring health plans to cover COVID-19 testing and related services. Specifically, these FAQs address the services commercial health plans are required to cover (Q7) and clarifies the legislation includes ERISA plans (Q1) in the requirement to waive cost sharing for COVID-19 testing and related services. 
• Medicare Cost Sharing for COVID-19 Testing: The Families First Coronavirus Response Act waives cost-sharing under Medicare Part B (coinsurance and deductible amounts) for COVID-19 testing-related services through the end of the public health emergency. In April, CMS provided evaluation and management categories for applicable medical visits. CMS now specifies HCPCS procedure codes for this cost-sharing waiver for services provided by clinicians paid under the physician fee schedule, in HOPDs paid under OPPS, and in RHCs and FQHCs. 
• CARES Act Summary: The Families First Coronavirus Response Act (Public Law 116-127) was signed into law on March 18, 2020. The Coronavirus Aid, Relief, and Economic Security Act or “CARES Act” (Public Law 116-136) was enacted into law shortly thereafter on March 27, 2020. This summary addresses those provisions in each Act that relate to the Medicare, Medicaid and Children’s Health Insurance Programs, the Public Health Service Act, and other provisions relating to certain health care programs of the Department of Health and Human Services (HHS).

Medicare – General

• Center for Medicare and Medicaid Innovation – COVID-19 Flexibilities: On June 3^rd, CMMI announced new flexibilities and adjustments to current and future Center for Medicare and Medicaid Innovation (CMMI) models to address the emergency.
• Interim Final Rule on COVID-19 Part II: On April 30, CMS released an additional interim final rule allowing hospitals to increase capacity, expanding the types of providers who can bill for telehealth services, allowing the patient’s home to be considered an HOPD for telehealth services, and providing additional flexibility for MSSP participants. HFMA’s executive summary is available here.
• Fact Sheet: Developing Alternative Care Sites with State and Local Governments: This newly published fact sheet provides state and local governments developing alternate care sites with information on how to seek payments through CMS programs – Medicare, Medicaid, and the Children’s Health Insurance Program (CHIP) – for acute inpatient and outpatient care furnished at the site.
• COVID-19 Blanket Swing Bed Waiver for Addressing Barriers to Nursing Home Placement for Hospitalized Individuals: CMS issued a new MLN article that answers key questions about providing skilled nursing level care for hospitalized patients who do not need acute level care but cannot find nursing home placement during the COVID-19 Public Health Emergency.
• COVID-19 Frequently Asked Questions (FAQs) on  Medicare Fee-for-Service (FFS) Billing: The FAQs in this document supplement the following previously released FAQs: 1135 Waiver FAQs and Without 1135 Waiver FAQs. We note that in many instances, the general statements of the FAQs referenced above have been superseded by COVID-19-specific legislation, emergency rules, and waivers granted under section 1135 of the Act specifically to address the COVID-19 public health emergency (PHE).  The policies set out in this FAQ are effective for the duration of the PHE unless superseded by future legislation.
• Expansion of The Accelerated and Advance Payments Program For Providers And Suppliers During Covid-19 Emergency:  CMS issued guidance detailing how providers can access accelerated Medicare payments, as modified by the CARES Act to provide needed liquidity during the COVID-19 pandemic. This fact sheet provides details how hospitals and physicians can access these funds and how they will be repaid.
• Interim Final Rule in Response to COVID-19: On March 30^th, CMS issued a rule that allows hospitals to increase capacity, increase the types of services that can be provided virtually, and reduce administrative burden.
• Requirements for Notification of Confirmed and Suspected COVID-19 Cases Among Residents and Staff in Nursing Homes: CMS issued a memo and frequently asked questions addressing the new requirement that nursing homes and long term care facilities report COVID-19 facility data to the Centers for Disease Control and Prevention (CDC) and to residents, their representatives, and their families. This action, included in the recent Interim Final Rule with Comment Period, will support surveillance of COVID-19 cases and increase transparency.
• 2019 Novel Coronavirus (COVID-19) Long-Term Care Facility (LTC) Transfer Scenarios: CMS is providing supplemental information for transferring or discharging residents between skilled nursing facilities (SNFs) and/or nursing facilities based on COVID-19 status (i.e., positive, negative, unknown/under observation).
• COVID-19 National Emergency Declaration Fact Sheet: Describes in general what Medicare regulations will be waived in response to the COVID-19 national emergency declaration.
• Provider Enrollment Simplification: Provides answers to frequently asked questions about CMS’s actions to reduce administrative barriers to enrolling additional providers in response to the COVID-19 national emergency.
• Relief for Hospitals and Providers Participating in Quality Reporting/Payment Programs: CMS announced it is granting exceptions from reporting requirements and extensions for clinicians and providers participating in Medicare quality reporting programs with respect to upcoming measure reporting and data submission for those programs. See appendix I below for specific details for each program.
• Quality Payment Program COVID-19 Factsheet: Outlines the Merit-based Incentive Payment System (MIPS) extreme and uncontrollable circumstances policy and procedures for MIPS eligible clinicians affected by COVID-19.
• COVID-19 Test Pricing: Provides payment amounts by MAC based on HCPCs code used.
• Increased Payment for High-Throughput COVID-19 Lab Tests: Medicare has increased payment for COVID-19 tests processed on high-volume machines. The payment for these tests is approximately $100. A high-volume machine is one that processes more than 200 specimens per day. The guidance provides examples of the machines that are currently considered high-volume and gives the specific G codes that should be used to bill for tests processed on these machines.

Telehealth Billing

• Changes in Medicaid Telehealth Policies Due to COVID-19 – Catalog Overview and Findings: In response to the novel coronavirus (COVID-19) pandemic, states have used Medicaid program flexibilities to increase use of telehealth in unprecedented ways. To ensure beneficiary access to services during the emergency period of the pandemic, states have expanded the primary care, acute, and specialty services that can be provided via telehealth; the provider types who may use telehealth; and the permissible modalities. This summary report synthesizes key findings from across the states. The catalog provides high level, state-specific information on telehealth policy changes pertaining to services and specialties, providers, modalities, originating site and licensure rules, and payment.
• Telehealth Provider Fact Sheet: Provides an overview of Medicare’s expanded telehealth benefit during the national emergency.
• Telehealth Billing FAQs: Provides CMS’s answers to frequently asked questions related to billing Medicare for telehealth.
• Telehealth Toolkit: CMS has produced a “telemedicine toolkit” with links to internet resources. Many of these links will help providers learn about the general concept of telehealth, choose telemedicine vendors, initiate a telemedicine program, monitor patients remotely, and develop documentation tools. Additionally, the information contained within each toolkit will also outline temporary virtual services that could be used to treat patients during this specific period of time.
• RHC & FQHCs: Telehealth and Virtual Communications Flexibilities During COVID-19 Public Health Emergency: To support Rural Health Clinics (RHCs), Federally Qualified Health Centers (FQHCs), and their patients, Congress and CMS made changes to requirements and payments during the COVID-19 Public Health Emergency, including, new payment for telehealth services ( including billing instructions), expansion of virtual communication services, revision of home health agency shortage requirement for visiting nursing services, consent for care management and virtual communication services, and additional information on accelerated/advance payments.
• Nursing Home Telehealth Toolkit: CMS has produced a “telemedicine toolkit” with links to internet resources. Many of these links will help nursing homes learn about the general concept of telehealth, choose telemedicine vendors, initiate a telemedicine program, monitor patients remotely, and develop documentation tools. Additionally, the information contained within each toolkit will also outline temporary virtual services that could be used to treat patients during this specific period of time.

State Action

• Medicaid FMAP Increase FAQs: CMS has released a FAQ related to the 6.2 percentage point increase in Federal Medicaid Assistance Percentage (FMAP) in the Families First Coronavirus Response Act.
• Approved State Medicaid Waivers Related to COVID-19: Despite the national emergency, states must apply for section 1135 waivers to relax certain federal requirements in response to COVID-19.  This tool tracks which states have had waivers approved and what the waiver covers.
• State Policy Actions Related to COVID-19: The Kaiser Family Foundation has created a resource tracking which states have eliminated cost sharing for testing and treatment related to COVID-19 for the health plans they regulate.

Commerical Coverage

• Health Insurer COVID-19 Coverage: America’s Health Insurance Plans (AHIP) provides an up-to-date list of its members’ coverage policies for testing and services related to COVID-19 for fully insured products.
• FAQs on Essential Health Benefits Related to COVID-19: Provides HHS’s answers to frequently asked related to coverage for testing and treatment related to COVID-19.

Disaster Planning, Financing and Reimbursement

• HFMA Disaster Planning Checklist: Provides CFOs with a checklist to help their organizations prepare for events like the COVID-19 national emergency.
• CDC Disaster Planning Budget Tool: Currently, the industry doesn’t have clarity into how HHS will request documentation to support claims for reimbursement from the Public Health and Social Services Emergency Fund. However, it is anticipated that hospitals will be asked to accurately segregate the costs related to disaster response from normal operating costs. Keys to this will include accurate coding of pneumonia/COVID-19 cases, capture of direct costs in a discrete cost center, and documentation to support allocations of time from staff and resources that are split amongst activities. The CDC’s Disaster Budget Planning Tool is one example of a model providers could follow. While there’s no guarantee HHS will follow this model, it is a format one of their agencies has put forth as an approach.

General

• HFMA COVID-19 News Coverage: Stay up-to-date with the most current reporting on the crisis as it impacts health plans, hospitals, and physicians from DC and beyond.
• Catholic Health Association Community Benefit Guidance: The CHA is providing preliminary suggestions for reporting community benefit expenses using the categories from Part I of the Internal Revenue Service (IRS) Form 990 Schedule H and the Catholic Health Association (CHA) Guide for Planning and Reporting Community Benefit.
• EMTALA Requirements Related to COVID-19: Provides an overview of acute care hospital requirements related to screening and treatment related to COVID-19.
• CMS Guidance on Elective Procedures – Phase I Reopening:  This link includes CMS’s recommendations to postpone non-essential surgeries and other procedures to conserve critical healthcare resources and limit exposure of patients and staff to COVID-19 during “Phase I” of reopening. Developed in collaboration with medical societies and associations, the recommendations outline a tiered approach for state and local officials, clinicians, and delivery systems to consider to prioritize services and care to those who require emergent or urgent attention to save a life, manage severe disease, or avoid further harms from an underlying condition.
• CMS Guidance on Non-Emergent Care – Phase II Reopening: This document provides the administration’s guidance to healthcare providers and systems for delivering non-emergent care if its state or region shows no evidence of COVID-19 rebound and satisfies the administration’s “gating criteria” for Phase II. CMS is providing these recommendations to ensure that non-emergency healthcare resumes safely and that patients are receiving needed in-person treatment that may have been postponed due to the public health emergency.
• What Patients Should Know About Seeking Care: To aid patients in making a decision that is right for them, CMS issued recommendations to help guide patients as they consider seeking in-person, non-emergency treatment. Ultimately, patients should rely on their providers’ suggested course of treatment.
• State Actions on Reopening Non-Emergent Procedures: Alston Bird provides a tracker following state requirements related to non-emergent procedures. 
• CMS Recommendations on Re-Opening Facilities to Provide Non-Emergent Care: The recommendations update earlier guidance (above) provided by CMS on limiting non-essential surgeries and medical procedures. They recommend a gradual transition and encourage health care providers to coordinate with local and state public health officials, and to review the availability of personal protective equipment (PPE) and other supplies, workforce availability, facility readiness, and testing capacity when making the decision to re-start or increase in-person care. Prior to resuming some non-emergent procedures, states or regions need to pass gating criteria regarding symptoms, cases, and hospitals. The CMS recommendations are not meant to be implemented by every state, county, or city at this time and Governors and local leaders ultimately need to make decisions on whether they are appropriate for their communities.

Additional publications

• COVID-19: Implications for business: McKinsey & Company’s latest perspective on the business implications of the pandemic.
• Beyond coronavirus: The path to the next normal: McKinsey & Company’s take on how leaders can begin navigating toward what’s next.

Appendix I: