COVID-19 and Practice Management and Billing

1. My group and I have been hit hard financially. Where can I find information on economic relief, loans and other programs?

• We have created a set of resources regarding economic relief for practices impacted by COVID-19. We realize that many practices and individuals are struggling financially as caseloads and patient populations have shifted.
  • The CARES Act established a Provider Relief Fund (PRF) to channel aid to healthcare systems and practices. Providers that receive PRF payments exceeding $10,000 in aggregate are required to report their use of funds, as per the program Terms and Conditions. HHS has released a summary of those terms (PDF) as well as when reporting must take place. 
  • The Small Business Administration’s Paycheck Protection Program provides loans to healthcare practices and all businesses. Applications are submitted through local and regional banks. If the funds are used within established criteria, the loan may be forgiven.
• Our advocacy division continues to seek economic relief via legislative and regulatory avenues for anesthesiologists and their groups.

2. Where can I learn more about Medicare’s Accelerated and Advance Payment program – including information on how to apply?

• This program was discontinued on April 26, 2020. Practices that did receive money from their Medicare Administration Contractor (MAC) (PDF) through this program will see that the MAC will begin recouping these funds by withholding payment of claims the practice submits for care to Medicare FFS beneficiaries. These terms have been revised and, at present, repayment starts one year from the date the payment(s) were issues. Starting from that point, and for the next 11 months, recoupment will be 25% of the amounts Medicare issues to the practice for submitted claims for services. After that 11 month period, recoupment increases to 50% and will continue for another six months. After that point, the MAC will issue a letter requesting payment for any remaining balance. Any remaining payment 30 days from that letter will be subject to interest (current rate is 4%). 

3. How can an anesthesia group bill for ICU services? We may also need to use our CRNAs as overflow ICU nurses and anesthesiologists as intensivists.

• Anesthesiologist may be called to serve as intensivists to care for COVID-19 patients.  This care may be reported as critical care services, (CPT® codes 99291, 99292). They may also be providing other services included ventilation management CPT code 94002, 94003) and other services. CPT includes detailed instructions on the proper reporting of these services. We recommend you work with your coding department on appropriate documentation and billing.
• For greater detail on billing, please visit the Timely Topics in Practice Management webpage. We recommend you work with your coding department on appropriate documentation and billing.

4. Has CMS released any information on appropriate billing during this period or healthcare waivers?

• Yes, CMS has issued a comprehensive set of FAQs on Medicare Fee for Service (PDF) billing in relationship to COVID. This CMS document includes information on the flexibilities associated with billing for care under the 1135 waivers that are in effect during the Public Health Emergency. The document updated on July 28, 2020.
• Another excellent CMS resource (last updated November 9, 2020) is the MLN Matters special edition article SE20011 (PDF). The FAQs and SE20011 are subject to updates so we recommend you not rely on an old version that you have downloaded but regularly check for recent updates.

5. Where can I learn more about Telehealth to determine if that may be a good option for my patients and my practice?

• Please refer to the CMS MLN Matters special edition article SE20011 (PDF), updated on November 9, 2020 for information on telemedicine. ASA has also provided several FAQs and background material on telehealth during the Public Health Emergency.

6. Where can I find more about Medicare Provider Enrollment Relief during the COVID emergency?

• CMS has updated its Medicare Provider Enrollment Relief FAQs (PDF).
  
   

7. Where do I ask compliance questions about federal relief and the appropriate management and use of federal relief funds?

• The US Department of Health and Human Services Office of Inspector General has published its FAQs on the “Application of OIG's Administrative Enforcement Authorities to Arrangements Directly Connected to the Coronavirus Disease 2019 (COVID-19) Public Health Emergency.”

8. Has CMS suspended the Quality Payment Program and Merit-based Incentive Payment System (MIPS) reporting?

• For 2020, CMS will be using its Extreme and Uncontrollable Circumstances policy to allow clinicians and groups to submit an application requesting reweighting of one or more Merit-based Incentive Payment System (MIPS) performance categories due to the current COVID-19 public health emergency. Individuals and groups must apply to CMS via their HCQIS Access Roles and Profile (HARP) account by February 1, 2021 to be considered for a hardship exemption.
• CMS acknowledged the role anesthesiologists and their groups have taken as part of the COVID-19 response. CMS has provided guidance on which Improvement Activities anesthesiologists and their groups should attest to in order to receive appropriate credit. In addition, the Anesthesia Quality Institute (AQI) National Anesthesia Clinical Outcomes Registry (NACOR) is supporting, the COVID-19 Clinical Trials Improvement Activity for performance year 2020.
• Materials for the 2021 Quality Payment Program have been posted on the CMS website. 

Additional Information

• General
• Anesthesia Machines and Equipment Maintenance
• Clinical Care
• Elective Surgery
• Federal Advocacy
• Hospital and Facility Administration
• Occupational Safety and Wellness
• Personal Protective Equipment
• Patient Testing

Disclaimer

Viewers of this material should review these FAQs with appropriate medical and legal counsel and make their own determinations as to relevance to their particular practice setting and compliance with state and federal laws and regulations. The ASA has used its best efforts to provide accurate information. However, this material is provided only for informational purposes and does not constitute medical or legal advice. This response also should not be construed as representing ASA policy (unless otherwise stated), making clinical recommendations, dictating payment policy, or substituting for the judgment of a physician and consultation with independent legal counsel.