Rev Cycle Assist COVID-19 Response
We’d like to begin by extending our deepest thanks to everyone working in the healthcare field. The sacrifices you make to protect our communities and keep patients safe are nothing short of heroic and all of us at Rev Cycle Assist are very grateful for the incredible work you do.
The COVID-19 crisis is impacting every facet of the healthcare industry. Of course, patient care and the safety of your staff are at the top of the list of concerns. However, due to new regulatory flexibilities, this virus also affects how you manage claims and billing and these areas must be addressed as well.
We want you to know that as always, our team at Rev Cycle Assist is here to keep track of the ever-changing government/payer regulations and compliance laws related to your billing cycle, so that you can focus your time and attention on the crisis at hand.
To start, we’ve reviewed the recent CMS document, COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers, and we’d like to bring a few items to your attention that could affect your revenue cycle and registration process with uninsured and under-insured patients. The blanket waivers have a retroactive effective date of March 1, 2020 until the end of the emergency declaration.
SNF Placement Waiver
- Waives the 3-day prior hospitalization requirement for coverage of a SNF stay for those affected by COVID-19
- For some beneficiaries who recently exhausted their SNF benefits, this waiver authorizes renewed SNF coverage without having to start a new benefit period (“for those beneficiaries who have been delayed or prevented by the emergency itself from commencing or completing the process of ending their current benefit period and renewing their SNF benefits that would have occurred under normal circumstances,” as stated by CMS).
Critical Access Hospitals (CAH) Length of Stay Waiver
- Waives the limit of 25 beds
- Waives the 96-hour length of stay limit
States and territories can also submit a request for a waiver of certain regulations related to Medicaid and CHIP programs using the 1135 waiver checklist; these may include:
- Waiving prior authorization requirements in fee-for-service programs for those affected by COVID-19
- Permitting out-of-state providers to provide care to another state’s Medicaid enrollee impacted by COVID-19
CMS has already approved some of California’s Medicaid 1135 Waiver Requests. The approval statement includes these highlights:
- Waives or modifies “the state plan prior authorization requirements and processes for benefits administered through the fee-for-service delivery system.”
- Extends “pre-existing authorizations for which a beneficiary has previously received prior authorization through the end of the public health emergency.”
- Allows flexibility for “scheduling of Medicaid fair hearings and issuing fair hearings decisions during the emergency period.”
- “California may reimburse otherwise payable claims from out-of-state providers not enrolled in California Medicaid program” if certain criteria are met.
- “If a certified provider is enrolled in Medicare or with a state Medicaid program other than California, California may provisionally, temporarily enroll the out-of-state provider for the duration of the public health emergency in order to accommodate participants who were displaced by the emergency.”
- Allows “California to enroll providers who are not currently enrolled with another SMA or Medicare” if the state meets certain minimum requirements.
- Approves “California’s request to temporarily cease revalidation of providers who are located in California or are otherwise directly impacted by the emergency.”
- “These provider enrollment emergency relief efforts also apply to the Children’s Health Insurance Program (CHIP) to the extent applicable.”
We can help you navigate new rules and any other challenges you may face concerning out-of-state Medicaid billing and claims management. Our goals are to support you through this difficult time and keep you updated on new/temporary laws and changes in our industry.
Please contact us with any questions or for more information on the new regulatory flexibilities.