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.
- 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.
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 6th. FAQs are available here.
CARES Act Relief Funding
- 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.
- Distribution to COVID-19 Hotspots: Recognizing the particular impact the COVID-19 pandemic has had on hospitals in certain parts of the nation, and that inpatient admissions are a primary driver of costs to hospitals related to COVID-19, HHS is distributing $12 billion to 395 hospitals who provided inpatient care for 100 or more COVID-19 patients through April 10, 2020, $2 billion of which will be distributed to these hospitals based on their Medicare and Medicaid disproportionate share and uncompensated care payments.
These 395 hospitals accounted for 71 percent of COVID-19 inpatient admissions reported to HHS from nearly 6,000 hospitals around the country. The distribution uses a simple formula to determine what each hospital receives: hospitals are paid a fixed amount per COVID-19 inpatient admission, with an additional amount taking into account their Medicare and Medicaid disproportionate share and uncompensated care payments.
- Distribution to Rural Providers: Recipients of the $10 billion rural distribution will include, rural acute care general hospitals and Critical Access Hospitals (CAHs), Rural Health Clinics (RHCs), and Community Health Centers located in rural areas.
Hospitals and RHCs will each receive a minimum base payment plus a percent of their annual expenses. This expense-based method accounts for operating cost and lost revenue incurred by rural hospitals for both inpatient and outpatient services. The base payment will account for RHCs with no reported Medicare claims, such as pediatric RHCs, and CHCs lacking expense data, by ensuring that all clinical, non-hospital sites receive a minimum level of support no less than $100,000, with additional payment based on operating expenses. Rural acute care general hospitals and CAHs will receive a minimum level of support of no less than $1,000,000, with additional payment based on operating expenses.
- 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.
- General Distribution FAQs: Provides FAQs on terms and conditions and data required by HHS to support payments from the CARES Act Provider Relief Fund.
- Distribution of the Remaining Initial Appropriation of CARES Act Provider Relief Funding: HHS plans to distribute the initial $100 billion appropriated to the CARES Act Provider Relief Fund as follows:
- Providers: HHS will begin distribution of the remaining $20 billion of the general distribution to these providers on April 24 to augment their allocation so that the whole $50 billion general distribution is allocated proportional to providers' share of 2018 net patient revenue. On April 24, a portion of providers will automatically be sent an advance payment based off the revenue data they submit in CMS cost reports. Providers without adequate cost report data on file will need to submit their revenue information to a portal opening this week linked on this page for additional general distribution funds.
- High COVID-19 Impact Areas: $10 billion to distribute to hospitals in areas that have been particularly impacted by the COVID-19 outbreak. The distribution will be calculated using data submitted to HHS by 11:59 PT on Thursday, April 23, 2020. Details on the data request are available here. The announcement does not state when these distributions will begin.
- Rural Providers: $10 billion will be allocated for rural health clinics and hospitals. This money will be distributed as early as next week on the basis of operating expenses, using a methodology that distributes payments proportionately to each facility and clinic.
- Indian Health Service: $400 million will be allocated for Indian Health Service facilities, distributed on the basis of operating expenses. Payments will begin as early as next week.
- Safety Net Providers: An additional allocation will be made to skilled nursing facilities, dentists, and providers that solely take Medicaid. The release does not detail how much is provided for safety net providers, how the funds for these providers will be allocated, and when the distribution will occur.
- 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. For more information, visit coviduninsuredclaim.hrsa.gov. The release notice does not provide a specific amount allocated for uninsured COVID-19 patients.
- 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.
- Distribution of 1st Tranche of $30B in Relief Funding: HHS has released details on how the first $30B in provider relief funding from the CARES Act will be distributed. All facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible for this initial rapid distribution. Providers will be distributed a portion of the initial $30 billion based on their share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019. A provider can estimate their payment by dividing their 2019 Medicare FFS (not including Medicare Advantage) payments they received by $484,000,000,000, and multiply that ratio by $30,000,000,000. Providers can obtain their 2019 Medicare FFS billings from their organization's revenue management system.
- 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.
- 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
- 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 30th, 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.
Medicare – Telehealth Billing
- 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.
- 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.
- 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.
- 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: CMS recently updated recommendations to postpone non-essential surgeries and other procedures to conserve critical healthcare resources and limit exposure of patients and staff to COVID-19. 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.
- 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.
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