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Healthcare + Finance Leaders: Reimbursement/Cash Flow Strategies

1. New Survey Guidance
In response to the national emergency declaration as a result of COVID-19, CMS has recently issued a new memorandum to State Survey Agency Directors. For a 3-week time period only, beginning 3/20/20, the following survey types will be prioritized:

  1. Complaint/facility-reported incident surveys that are triaged at the Immediate Jeopardy (IJ) level. A streamlined Infection Control review tool will also be utilized during these surveys, regardless of the Immediate Jeopardy allegation.
  2. Targeted Infection Control Surveys of providers identified through collaboration with the Centers for Disease Control and Prevention (CDC) and the HHS Assistant Secretary for Preparedness and Response (ASPR).
  3. Self-assessments: The Infection Control checklist referenced above will also be shared with all providers and suppliers to allow for voluntary self-assessment of their Infection Control plan and protections.

During this prioritization period, standard surveys and revisits not associated with IJ are among those that will not be authorized but initial certification surveys will continue in accordance with current guidance and prioritization.

The Focused Infection Control Survey is available to every provider in the country to make them aware of Infection Control priorities during this time of crisis, and providers and suppliers may perform a voluntary self-assessment of their ability to meet these priorities. This shift in approach will allow health care providers time to implement the most recent infection control guidance from both CMS and the Centers for Disease Control and Prevention (CDC). At the same time, we are doing our duty to protect patients from harm, and ensuring providers are implementing actions to prevent the spread of COVID-19.

2. PEPPER – Program for Evaluating Payment Patterns Electronic Report
The PEPPER Team has announced that CMS is taking measures to free up the attention of providers as they respond to the coronavirus (COVID-19) pandemic. To this end, the planned April 6, 2020, release of the Q4FY19 PEPPERs for CAHs, LTACHs, IPFs, IRFs, hospices, and SNFs has been delayed.

As more information becomes available, the PEPPER Team will notify providers about the rescheduled release date for the Q4FY19 PEPPERs.

3. CMS Waivers under Social Security Act Issued
The Centers for Medicare & Medicaid Services (CMS) has authorized nationwide waivers under §1812(f) of the Social Security Act retroactive to March 1, 2020, for those impacted by COVID-19. As a part of this effort, most Medicare Fee-For-Service (FFS) medical reviews have been suspended during the Public Health Emergency (PHE) period for the COVID-19 pandemic.

This includes pre-payment medical reviews conducted by Medicare Administrative Contractors (MACs) under the Targeted Probe and Educate program, and post-payment reviews conducted by the MACs, Supplemental Medical Review Contractor (SMRC) reviews and Recovery Audit Contractor (RAC). No additional documentation requests will be issued for the duration of the PHE for the COVID-19 pandemic. Targeted Probe and Educate reviews that are in process will be suspended and claims will be released and paid. Current post-payment MAC, SMRC, and RAC reviews will be suspended and released from review. This suspension of medical review activities is for the duration of the PHE.

It is important to note that CMS may conduct medical reviews during or after the PHE if there is an indication of potential fraud and documentation requirements for skilled necessity remain unchanged. Additionally, any claims already in the appeal process will need to continue to be submitted per normal appeal processes. For ADRs that have already been issued, Medicare contractors will release the claims for payment and not issue claim denials. Any claims auto-denied for non-response of an ADR from March 1, 2020, until March 26, 2020, will have the denial reversed and allow payment if an appeal has not been filed. As of March 26, 2020, future ADRs will not be sent until further notice from CMS. See this FAQ for additional details.

C2C, the QIC who completed second-level Medicare Part A and Part B fee-for-service claims appeals for Jurisdiction K Part A and B as well as Jurisdiction 6 Home Health and Hospice, is limiting their on-site mail room operations in response to the COVID-19 public health emergency. As a result, C2C is requesting that any new second-level appeals be submitted via fax or their electronic portal rather than through mail. For additional information, including fax numbers and a link to their portal, please visit the C2C website.

Tags: COVID-19, Coronavirus