On March 6, 2020, President Trump signed into law the Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020. On January 31, 2020, Health and Human Services (HHS) Secretary Azar declared a public health emergency effective January 27, 2020, affording the Centers for Medicare & Medicaid Services (CMS) the flexibility to quickly support Medicare beneficiaries.
Following is a summary of important CMS actions and announcements related to patient care and coverage at this time.
Billing, Coding, and Coverage
CMS developed three new Healthcare Common Procedure Coding System (HCPCS) codes for Coronavirus lab tests:
- HCPCS code U0001 – Used specifically for Centers for Disease Control and Protection (CDC) testing laboratories to test patients for SARS-CoV-2 (CDC 2019 Novel Coronavirus Real Time RT-PCR Diagnostic Test Panel).
- HCPCS billing code U0002 – Allows laboratories to bill for non-CDC laboratory tests for SARS-CoV-2/2019-nCoV (COVID-19). Additionally, the Food and Drug Administration (FDA) issued a new policy for certain laboratories to develop their own validated COVID-19 diagnostics. HCPCS code U0002 may be used for tests developed by these additional laboratories when submitting claims to Medicare or health insurers.
Claims processing systems will begin accepting these codes on April 1, 2020 for dates of service on or after February 4, 2020. Until Medicare establishes national payment rates, rates will be set by the Medicare Administrative Contractors (MACs).
Original Medicare: As with other lab tests, beneficiaries will have zero cost-sharing.
Medicare Advantage (Medicare Advantage): MA organizations may waive or reduce enrollee cost sharing for Novel Coronavirus (COVID-19) laboratory tests provided they do so for all enrollees on a uniform basis. Telehealth and Other Communication-Based Technology Services
Original Medicare: CMS announced that beneficiaries may initiate “virtual check-ins” with their doctors when they have an established relationship. These brief communications must be unrelated to any previous evaluation and management visit. Physicians must bill the appropriate code: G2010 or G2012. Beneficiary cost-sharing and deductibles apply.
Beneficiaries may also initiate virtual communication with their physician over a 7-day window through an online patient portal. Physicians bill the appropriate code: 99421-99423, G2061-G2066. Beneficiary cost-sharing and deductibles apply.
Typically, only Medicare beneficiaries living in rural areas have access to full physician visits with their doctors through telehealth visits. Bipartisan legislation signed into law March 6, 2020, waived certain telehealth rules and will now provide beneficiaries, regardless of geography, access to telehealth services during this public health emergency. The beneficiary may receive telehealth services anywhere, including in the home, through real-time audio and visual communication. Beneficiary cost-sharing and deductibles apply.
Medicare Advantage: Beneficiaries enrolled in MA have access to telehealth services regardless of geography (i.e. not limited to rural areas) and from a variety of places, including the beneficiary’s home. MA beneficiaries can receive clinically appropriate treatment for COVID-19 through telehealth services.
Requests for Early Prescription Refills CMS announced that MACs will consider on a case by case basis whether to pay for greater than a 30-day supply of a Part B drug. Variables included in consideration are the nature of the drug, the patient’s diagnosis, the extent and likely duration of disruptions to the drug supply chain during an emergency, and other relevant factors to determine if the advanced refill is reasonable and necessary.
Vaccines: When a vaccine for COVID-19 is available, all Part D plans will be required to cover the vaccine.
Quality, Safety, and Oversight: On March 4, 2020 CMS released three Quality, Safety & Oversight (QSO) memoranda identifying modifications to the survey and certification processes asking healthcare providers to focus on infection control and prevention of COVID-19.
The first QSO memo limits and prioritizes survey activity:
- Immediate jeopardy complaints and allegations of abuse and neglect;
- Complaints alleging infection control concerns, including facilities with potential COVID-19 or other respiratory illnesses;
- Statutorily required surveys (i.e., nursing home, home health, hospice and ICF/IID facilities);
- Revisits necessary to resolve current enforcement actions;
- Initial certifications;
- Surveys of facilities/hospitals with a history of infection control deficiencies at an immediate jeopardy level during the last three (3) years; and
- Surveys of facilities/hospitals/dialysis centers with a history of infection control at a level below immediate jeopardy.
The second QSO focuses on hospitals and provides detailed guidance on screening visitors and patients and monitoring and restricting healthcare facility staff from working in case of exposure. The QSO states that hospitals should identify visitors and patients at risk for having COVID-19 infection before or immediately upon arrival to the healthcare facility. They should ask patients about the following:
- Fever or symptoms of a respiratory infection, such as a cough and sore throat.
- International travel within the last 14 days to restricted countries.
- Contact with someone with known or suspected COVID-19.
In addition, if a patient is under investigation for COVID-19, the QSO states hospitals should:
- Implement respiratory hygiene and cough etiquette (i.e., placing a facemask over the patient’s nose and mouth if that has not already been done) and isolate the patient in an examination room with the door closed.
- If the patient cannot be immediately moved to an examination room, ensure the patient is not allowed to wait among other patients seeking care. Identify a separate, well-ventilated space that allows waiting patients to be separated by 6 or more feet, with easy access to respiratory hygiene supplies.
- Inform infection prevention and control services, local and state public health authorities, and other healthcare facility staff as appropriate about the presence of a person under investigation for COVID-19.
Additional guidance for evaluating patients in U.S. for COVID-19 infection can be found on the CDC COVID-19 website.The same screening performed for visitors should be performed for hospital staff:
- Health care providers (HCP) who have signs and symptoms of a respiratory infection should not report to work
- Any staff that develop signs and symptoms of a respiratory infection while on-the-job, should:
- Immediately stop work, put on a facemask, and self-isolate at home
- Inform the hospital’s infection preventionist, and include information on individuals, equipment, and locations the person came in contact with
- Contact and follow the local health department recommendations for next steps (e.g., testing, locations for treatment)
- Refer to the CDC guidance for exposures that might warrant restricting asymptomatic healthcare personnel from reporting to work (www.cdc.gov/coronavirus/2019- ncov/hcp/…).
The third QSO is designed to help nursing homes limit the transmission of COVID-19, including guidance for monitoring or restricting staff and managing transfers and admissions of patients with suspected or confirmed COVID-19 infection.
Medicaid and CHIP CoverageCMS has released a fact sheet “Coverage and Benefits Related to COVID-19 Medicaid and CHIP”, which highlights areas of coverage generally as it varies from state to state. It does not specifically mention changes in coverage as it relates directly to COVID-19.
Exerpt from ASCO my Connection, March 9. 2020