What are the post PHE changes, that Medical Practices and Medical Billers, are required to track?
The COVID-19 pandemic emerged in 2020.
CMS announced flexibilities and waivers to address COVID challenges. After renewals, the COVID-19 PHE may soon end.
The recent extension revised the end of PHE from October to December, adding 90 more days. There are many speculations that this might be the last extension.
Review waivers and flexibilities during PHE as they near expiration or transition post-PHE.
Here are the main objectives:
- CMS ended some waivers and is evaluating others based on the current PHE phase.
- CMS is assessing which flexibilities would be most useful in a future PHE.
- CMS collaborates with partners to prepare the healthcare system for future emergencies.
Here are the few highlights:
Telehealth coverage and services will continue for 151 days (5 months) after the PHE ends. Face-to-face telehealth encounters are allowed post-PHE, and the waiver ends after 151 days.
Evaluation and Management Visits via Telehealth:
CMS is reinstating frequency limits on certain E/M telehealth services post-PHE. Level 1 E/M for COVID-19 specimen collection returns to pre-PHE requirements.
Behavioral and Preventive care Visits via Telehealth:
CMS permits behavioral health and education services via audio-only telehealth. The future of telehealth will be exciting nonetheless. Telehealth/telemedicine may continue post-PHE this year.
MIPS changes:
Did you miss the March 31, 2022 MIPS deadline? Did you miss the MIPS deadline? All categories were reweighted to 0% for a neutral 2023 payment. (Doesn't apply to groups, virtual groups, or APM Entities)
Referrals and Stark Law:
Stark bars physician referrals to financially tied entities for Medicare/Medicaid, with exceptions. Stark referral waivers end, reverting to the original Stark Law. Waivers end with PHE, requiring immediate Stark Law compliance.
DMEPOS Billing:
Part B drug/DME signature, delivery proof waived during PHE, reinstated after.
Vaccination Administration Billing:
COVID-19 vaccine payment aligns with other Part B vaccines after 1 year post-PHE. CMS pays $40 per dose for clinic COVID-19 vaccines and $75 per dose for home administration until PHE ends.
PHE ends, and the CARES Act price transparency requirement terminates. Price transparency requirements under other laws and regulations will continue to apply.
Credentialing:
PHE allowed telehealth from home without disclosing the address. PHE ends, and practitioners must report home addresses on Medicare enrollment.
In Conclusion:
Maintaining Compliance with these post pandemic changes can prove to be a challenge. Providers and billers must watch for state laws and comply fully. Providers may need to reassess business & care models as they've widely adopted telehealth.
Being non-compliant with changes might put some practitioners at risk of auditing & investigations. AltuMED can help keep you up with the challenges that might come with these changes. We help you stay compliant with new changes and updates.
AltuMED is a Healthcare Revenue Cycle Management technology and solutions company. Our technologically advanced Practice Management Software, PracticeFit optimizes the Medical Billing workflows for Medical Practices, Labs and Third-Party Medical Billing Companies helping them collect maximum revenue. Find out more.
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