Chargemaster Guide for the COVID-19 Public Health Emergency: Part 1 – COVID-19 PHE Background & Resources

This blog is a segment from our multi-part “ChargeAssist Update News” resource guide summarizing common charging, coding, and regulatory updates currently being addressed by Chargemaster and Revenue Cycle teams under the current public health emergency period. Proactive monitoring of CMS and other payer coding and claims requirements is more essential now than ever to ensure correct charging, billing and payments.

Introduction

If you’re like us, your e-mail inbox has exploded with news and regulatory updates related to COVID-19 and the Public Health Emergency Declaration (PHE). Based on current confusion about ‘what to charge’ and ‘how to charge’ for certain services during this emergency period, we thought we would share a summarized update of key CMS and AMA updates that may be impacting your Chargemaster and charge capture processes.

Today’s Industry Questions:

What has changed?
What can our organization charge for? 
What codes & modifiers should we use?
Where do we obtain timely guidance?
How do we stay current?  

CDM and Revenue Cycle teams are furiously reading, interpreting, communicating, and questioning the many regulatory documents released from payers. CMS, in particular, is continually providing publications, calls, and webcasts as more authorities are exercised and as some regulations and statutes are waived. Payers are largely following Medicare guidance on charging, coding and billing changes related to the COVID-19 responses of their organizations. However, there is still much variance in payer guidance.

This multi-part “ChargeAssist Update News” series provides helpful resource links and summarizes common charge-related challenges currently faced by CDM and Revenue Cycle teams.

Getting Started

As your team works through its Revenue Integrity emergency response plan, quickly setting up charges and coordinating on charge capture and billing are all essential priorities. CMS’s COVID-19 guidance has been fast and furious with many new forms of communications. A number of issues remain unanswered by CMS which is disheartening to hospitals facing claims holds until more specific guidance is released.  Operationally, we believe it is helpful for Hospital and Practice Management Revenue Integrity teams to collaborate on CMS and other payers’ guidance, as well as changes in delivery scenarios. Based on feedback from our customers, Revenue Integrity teams are now asking: 1) What has changed during the emergency declaration? 2) What can our organization charge for? 3) What codes and modifiers should we use? 4) Where do we obtain timely guidance? and 5) How do stay current as more changes unfold?

We’ll delve into some of these topics in this multi-part resource guide. Keep in mind – CMS and other payer guidance related to charge and claims data may change tomorrow, next week, or months from now. We are in a unique time. We feel that those who apply proactive strategies to understand this new delivery and payment environment will be less impacted financially and operationally during this time.

Public Health Emergency Declaration

First, let’s quickly talk about the Public Health Emergency (PHE) declaration. During this emergency period, designated by the government due to the COVID-19 pandemic, much has changed in healthcare. This extends from healthcare delivery to payment to regulations and more. An “Emergency Declaration” is defined as noted below:

 “The Secretary of the Department of Health and Human Services (HHS) may, under section 319 of the Public Health Service (PHS) Act, determine that: a) a disease or disorder presents a public health emergency (PHE); or b) that a public health emergency, including significant outbreaks of infectious disease or bioterrorist attacks, otherwise exists.

Duration and Notification: The declaration lasts for the duration of the emergency or 90 days, but may be extended by the Secretary. Congress must be notified of the declaration within 48 hours, and relevant agencies, including the Department of Homeland Security, Department of Justice, and Federal Bureau of Investigation, must be kept informed.

Prior to issuing the declaration, the Secretary should consult with public health officials as necessary.”

Watch for unfolding information on CMS waivers such as “1135 waivers” or “blanket waivers” as the COVID-19 pandemic continues. The U.S. Department of Health & Human Services website lists the authorities of the HHS Secretary following a section 319 declaration (PHE) here:   https://www.phe.gov/Preparedness/legal/Pages/phedeclaration.aspx

CMS Sources for COVID-19 Information

Often, it becomes difficult to keep up with source documents as the industry shares information and weighs in on appropriate revenue cycle and CDM use. The CMS Current Emergencies page has a 2020 Coronavirus section that we recommend as a bookmark on your browser. https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/Current-Emergencies-page.

As rulemaking documents are released through the Federal Register, CMS will provide PDF version of the rules. An example is the 221 page Interim Final Rule released 3/31/20 and specific to COVID response https://www.cms.gov/files/document/covid-final-ifc.pdf  This document is titled “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency” and was released in display copy on March 31, 2020. All providers should download this and future documents for specific guidance on various changes that have occurred with CMS rulemaking related to the COVID emergency. Tip: watch for another upcoming IRF in the coming days (rumored to be completed by CMS and awaiting GAO release.) Over time, we see Final Rule (Federal Register) details released through Transmittals, MLN Matters, and when applicable, they may be manualized in the CMS manuals. This often takes several weeks. CMS Pricer and Edit systems are also updated on the CMS schedules as well as HCPCS, CPT, ICD-10 and other coding data sets.

Industry Questions & CMS Clarifications

Many hospitals and consulting peers have found that it is essential to monitor CMS communications much more frequently. The timing of CMS communications should be considered to avoid missing updates.


The H&A consulting team has determined that the CMS Current Emergencies page website location noted above is an excellent centralized site for monitoring CMS updates on COVID-19 announcements and resources. This page is broken out with web links to various sites and reference documents. The Clinical and Technical guidance is broken out by “all clinicians”, all health care providers”, “healthcare facilities”, “labs”, “Programs of All-Inclusive Care for the Elderly (PACE) Organizations”. Importantly, there is a section called “Billing & Coding guidance” that houses various FAQs and Fact Sheets as well as MLN Matters articles. Simply look to the top of the listing for the most current updates.

Other subsections of this site may be helpful for various staff in your organization.

Keep in mind that material documented on the CMS site and in other publications may change as CMS either clarifies or changes guidance. For example, CMS continues to update their Frequently Asked Questions documents such as the recent version below.

The CMS Office Hours recordings and live calls are important for submitting questions to CMS and listening to audience concerns relative to billing issues during the Emergency period. The sessions occur on Tuesdays and Thursdays 5PM EDT with recorded versions available on the CMS podcast page about 3-4 days later. Some calls also have the meeting transcripts posted. Watch for FAQ updates at least weekly by visiting the updated document linked here: https://www.cms.gov/files/document/03202020-covid-19-508.pdf The CMS podcasts and transcripts are located here: https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts

AMA Sources for COVID-19 Information

Through a special AMA COVID-19 resource center AMA has released coding updates on testing codes as well as and guidance on telemedicine. The following link provides even more specific COVID-19 test code information from AMA – https://www.ama-assn.org/practice-management/cpt/covid-19-coding-and-guidance. Additionally, the public can download AMA’s Special CPT Assistant articles and monitor for other updates as they occur through this url without a publication subscription. ChargeAssist® subscribers, of course, receive this information as soon as it is posted. Keep in mind that much of the CPT guidance is targeted toward physician practice claims and services paid under the Medicare Physician Fee Schedule (MPFS) or the Clinical Laboratory Fee Schedule (CLFS). We do not see the CPT resources identifying unique coding and billing scenarios for hospitals at the current time.

Where to go for help

  1. Reach out to Peers: Utilize your network if your team would benefit from hearing from other hospitals that may have faced the COVID-19 crisis a bit earlier than your community.
  2. Utilize Trusted Consultants: Seek interpretations and input from Chargemaster consultants who have been intently reading, listening, and collaborating with others on CMS changes. A few hours of support or education can save significant time, and will ensure correct decisions on data updates in your Chargemaster or processes.
  3. Safeguard your data integrity with CDM Tools: We firmly believe that CDM resource tools are more important than ever for staying current on changing regulations, data, and payment rules during this time. Integrated payment and edit information that tools provide are often the best ‘clue’ for understanding CMS’ intent as they roll out information.
  4. Scale Down to Targeted Audits: And finally, even though it may not be time for large house-wide data review projects, selective auditing or pricing analyses may become even more critical as margins are impacted. Companies that have embraced remote engagements can deploy projects effectively even in today’s challenging times.

It’s already clear that the COVID pandemic is causing significant revenue losses from freezes in elective care and reduced inpatient capacity. Financial impacts will likely be felt for quite some time. As Revenue Cycle Teams slowly return to normal operations, Chargemaster management efficiency and data accuracy will be more essential than ever. Consulting Support, 1:1 Coaching/Education, Targeted Chargemaster Auditing, or better-priced Chargemaster software tools will be more important in the coming months than in any time in our professional careers in hospital Revenue Integrity.

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Author: Rosemary Holliday, MHA, Managing Partner Holliday & Associates/ChargeAssist

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