Accounting and Financial Reporting

HHS updates COVID-19 payment and reporting requirements

August 21, 2020 1:48 pm
  • CMS added new coronavirus testing requirements for hospitals seeking payment increases for COVID-19 patient care.
  • HHS delayed the release of reporting instructions for providers receiving COVID-19 grants.
  • Eighty children’s hospitals soon will receive $1.4 billion in targeted grants.

New COVID-19 testing requirements as a condition of receiving Medicare payment increases were among the recent developments affecting providers’ payments for pandemic-related care, as announced by HHS and CMS.

For all Medicare beneficiary admissions after Sept. 1, hospitals will need to document a positive COVID-19 lab test to receive the 20% increase in the case’s MS-DRG weighting factor, according to a CMS notice.

Positive results must be from viral testing (i.e., molecular or antigen) that follows CDC guidelines.

Other details on the new requirement include:

  • Allowing testing to be performed by entities other than the hospital
  • Performing the test within 14 days of the hospital admission
  • Allowing results to be manually entered into the patient’s medical record

As an example of an outside test that is eligible to be included in the medical record, CMS said hospitals can enter a copy of a positive COVID-19 result conducted by a local government-run testing center a week before the admission.

“In the rare circumstance where a viral test was performed more than 14 days prior to the hospital admission, CMS will consider whether there are complex medical factors in addition to that test result for purposes of this documentation requirement,” the agency stated.

CMS warned that post-payment medical reviews may be conducted to confirm the presence of a positive COVID-19 lab test. If no such test is contained in the medical record, “the additional payment resulting from the 20 percent increase in the MS-DRG relative weight will be recouped.”

If a hospital diagnoses a patient with COVID-19 and notes it using the ICD-10-CM code but does not have evidence of a positive test result, the hospital can decline the COVID-19 payment increase when submitting claims by informing its Medicare administrative contractor (MAC). The MAC will notate the claim with the appropriate internal claim-processing coding.

CARES Act paperwork deadline looms

Providers that accepted payments of at least $10,000 from the CARES Act Provider Relief Fund (PRF) will need to submit documentation to HHS starting Oct. 1 to show compliance with the fund’s terms and conditions. Each of the three rounds of PRF general distributions and the five targeted distributions has its own set of terms and conditions, all of which are located on the HHS PRF page.

Although details on the required data were supposed to be released Aug. 17, an HHS notice stated that the department “is continuing to refine its data elements and will provide those additional details at a date later than August 17, 2020.”

“Providers will still be given the detailed PRF reporting instructions and a data collection template with the necessary data elements they will be asked to submit well in advance of the reporting system being made available — which is currently targeted for October 1, 2020,” HHS stated.

Known requirements include:

  • Reporting on PRF grant spending through Dec. 31 within 45 days of the end of CY20
  • Allowing recipients to file a single final report if they spent all PRF funds before Dec. 31
  • Requiring recipients that don’t spend PRF funds by Dec. 31 to submit a second and final report by July 31, 2021.

Children’s hospital funding on the way

Almost 80 freestanding children’s hospitals will receive an additional $1.4 billion in targeted PRF funding, according to an HHS announcement.

Children’s hospitals have seen decreasing patient visits and increased costs, HHS noted.

“This distribution will help to ensure children’s hospitals receive relief proportional to other hospitals across the nation and providers caring for children are able to continue operating safely in some of our most vulnerable communities,” HHS stated.

Children’s hospitals suspended nonemergency surgeries, purchased additional personal protective equipment and offered their capacity as a backup to other hospitals in support of local preparedness planning for COVID-19 patient surges, according to HHS.

Other details of the payments include:

  • Limiting eligibility to exempt hospitals under the Inpatient Prospective Payment System or to children’s hospital graduate medical education facilities as defined by the Health Resources and Services Administration.
  • Providing payments equivalent to 2.5% of a recipient’s net revenue from patient care
  • Beginning payment distributions this week
  • Making payments conditional on accepting HHS’s terms and conditions

Recipients may be subject to auditing to certify the data provided to HHS for payment calculation is accurate.


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