In today’s environment, things are changing and/or being clarified rapidly. So, the purpose of this communication is to provide a quick summary of recent updates and the latest developments on the federal response to COVID-19. We’ll continue to keep a close eye on all of this and provide updates as appropriate.
CLICK HERE for our detailed FAQ document on all the various COVID-19 Economic Relief Programs
Healthcare Specific Economic Programs
Medicare Advanced/Accelerated Payment Program
What’s New? – As of April 9th, $51 billion dollars have been dispersed through the program. As directed by CMS, MACs have updated their applications to reflect the COVID-19 pandemic.
HHS Provider Relief Fund Payments
What’s New? – HHS has provided some clarification since releasing the funds last week, however there are still many questions remaining to be answered. HHS updated their initial guidance and clarified that care does not need to be specific to treating COVID-19 because HHS is broadly viewing every patient as a possible COVID-19 case. Even practices that have ceased operations are eligible to keep the funds as long as they provide patient care after January 31st, 2020.
HHS also updated their initial guidance on the attestation process. If recipients wish to keep the funds, and adhere to the Terms and Conditions, they are required to complete the attestation now available on the Provider Relief Fund website portal. If, on the other hand, they want to forego the funds and return them, HHS has stated the attestation portal will guide recipients through the process. Providers that have questions on accepting or rejecting the funds, or other questions, can call the CAREs Provider Relief Hotline at: (866-569-3522). If recipients fail to return the funds within 30 days of receiving payment, HHS will automatically assume they are accepting the terms and conditions. Details from HHS on the Provider Relief Fund, including the attestation portal, are available HERE
General Economic Stimulus Programs
Paycheck Protection Program
What’s New? – An interim final rule was released this week which makes updates to the PPP. Businesses may now apply for both PPP loans and Economic Injury Disaster loans (EIDL). However, the funds may not be used on the same expenses. Additionally, EIDL loans can now be turned into PPP loans. The SBA has updated their website to provide more resources for those wishing to apply for PPP loans – adding the application and a search tool to locate vendors supporting the program. As of 4/16/2020, appropriations (i.e. funding) for the PPP have lapsed and the SBA is unable to accept new applications. Applications that have already been submitted prior to the lapse in appropriations will still be processed. More appropriations should be coming in the next few weeks through the federal government – either through the passage of additional coronavirus legislation and/or the Federal Reserve’s Main Street Lending Program.
Economic Injury Disaster Loans (EIDL)
What’s New? – As mentioned, EIDL loans may be turned into PPP loans and borrowers can apply for both programs, as long as funds are not used for the same expenses. Now, applicants can request an advance payment of EIDL funds during the application process, up to $10,000 dollars, which does not need to be repaid. The advance amount is based on how many employees a business has, at $1,000 dollars per employee, and the total amount is removed from EIDL loan once it is granted. For example – a business applies for $100,000 in EIDL funds and qualified for $10,000 as an advance. This business would ultimately repay $90,000 of the loan.
Main Street Lending Program – Newly announced April 9th, the Main Street Lending program is a line of funding available through the Federal Reserve. This program is geared towards small to mid-sized businesses with up to 10,000 employees. The full application process still needs to be released, however a portion of the $2.3 trillion in funds will support the Paycheck Protection Program. For businesses seeking loans, the minimum amount starts and $1 million dollars. CLICK HERE for more information from the Federal Reserve.
Employee Retention Tax Credit
What’s New? – There have not been any changes to the Employee Retention Tax Credit since it’s initial announcement.
In mid-March, the Centers for Medicare and Medicaid Services (CMS) began making temporary adjustments to regulations and programs in order to support healthcare providers and beneficiaries during the public health emergency. These actions cover a wide variety of topics, including waiving certain rules and regulations for providers while expanding coverage for telehealth services and COVID-19 testing. CLICK HERE for more information on regulatory updates from the beginning of the month.
What’s New? – Over this past week, CMS has released more specific guidance on billing for telehealth services as well as cost sharing for COVID-19 testing.
- Telehealth – Last week, CMS clarified that billing for telehealth services should be done as though a service was performed in person but adding the -95 modifier to indicate telehealth. CMS provided some further clarifications on using teleconferencing during the health emergency. Specifically, providers who are using teleconferencing to interact with patients but are in the same location would be billed as a face to face visit and not as telehealth. For example, a physician may be face-timing a patient from outside their room at a hospital in order to avoid COVID-19 contamination. Additionally, CMS will now reimburse (at average rates) phone consultation codes which were previously not covered by Physicians can now bill the following:
- 99441 $14.44 for 5-10 minutes of medical discussion
- 99442 $28.15 for 11-20 minutes of medical discussion
- 99443 $41.14 for 21-30 minutes of medical discussion
- Place of service 11 for office
PAs and NPs will also be paid for their code family 98966-98968 at the same physician allowable.
- CMS updated their FAQ document on COVID-19 available HERE – Telehealth information begins page 20
- For our summary of telehealth updates as of 3/30/2020 – CLICK HERE
- Cost Sharing for COVID-19 testing under Medicare– Early COVID-19 legislation expanded Medicare coverage for COVID-19 testing for beneficiaries. While Medicare fully reimburses for COVID-19 testing, they have recently waived cost sharing for visits that result in the administration of COVID-19 testing which should be indicated by using the – CS modifier. More details are available HERE (link to Medicare Updates Billing Guidance on Cost Sharing for COVID-19 Testing doc)
- Cost Sharing for COVID-19 testing for Commercial Payers – On April 11th, CMS announced the requirement for group health plans and group and individual health insurance to cover both diagnostic testing and certain related items and services provided during a medical visit with no cost sharing. This includes urgent care visits, emergency room visits, and in-person or telehealth visits to the doctor’s office that result in an order for or administration of a COVID-19 test.
- Higher Reimbursement for COVID-19 lab tests – Effective April 14th, CMS will reimburse COVID-19 laboratory tests at $100 per test. The previous reimbursement rate was set at $51 per test.
More information, specifically on the HHS Provider Relief Fund and Main Street Lending Program, is expected to come in the upcoming weeks. As always, ADVOCATE will continue to keep you informed on the issues impacting medical groups as they develop.
Todd Walker Kirk Reinitz