The Centers for Medicare and Medicaid Services (CMS) has issued a Frequently Asked Questions (FAQs) Sheet responding to eight (8) FAQs regarding provider burden relief for COVID-19. Below is an overview of the FAQs Sheet issued by CMS.
- Is CMS suspending most Medicare Fee-For-Service (FFS) medical review during the Public Health emergency (PHE) period for the COVID-19 pandemic?
Yes. CMS has suspended most FFS medical review during the COVID-19 pandemic. This includes Medicare Administrative Contractor (MAC) reviews, Supplemental Medical Review Contractor (SMRC) reviews and Recovery Audit contractor (RAC) reviews. No additional documentation requests will be issued for the duration of the PHE for the COVID-19 Epidemic. However, note that CMS reserves the right to conduct medical reviews during the PHE if there is an indication of potential fraud.
- Is CMS waiving signature requirements on proof of delivery slips in response to the COVID-19 pandemic, for Dates of Service (DOS) within the PHE for the COVID-19 pandemic?
Yes. CMS is not enforcing the signature requirement. Suppliers should document in the medical record the appropriate date of delivery and that a signature was not able to be obtained due to COVID-19.
- Is CMS pausing the repetitive, scheduled non-emergent ambulance transport prior authorization model (the “Model”)?
Yes. Effective March 29, 2020, certain claims processing requirements for the Model will be paused in the following locations: Delaware, the District of Columbia, Maryland, New Jersey, North Carolina, Pennsylvania, South Carolina, Virginia and West Virginia for the duration of the PHE for COVID-19. Upon the end of the PHE for COVID-19, the MACs will conduct post-payment review on claims otherwise subject to the Model. Claims that have already received a provisional affirmative prior authorization decision and are submitted with an affirmed unique tracking number (UTN) will continue to be excluded from future medical review.
- The Model is currently scheduled to end on December 1, 2020. Given this pause, will CMS extend the model beyond that date?
No. CMS is not planning to extend the Model. If it does extend, CMS will provide proper public notice of the extension.
- How does this pause in the Model affect a determination as to whether the Model meets the criteria to be expanded nationwide, as provided under 1834(l)(16) of the Social Security Act, and any next steps for expansion?
The pause will not affect the expansion of the Model. CMS will continue its effort to prepare for expansion of the Model following the end of the PHE for COVID-19.
- How does this pause in the Model affect evaluation of the model?
CMS will take the pause into consideration when evaluating the Model. Those claims submitted during the pause will be reviewed through post-payment review and factored into the evaluation.
- Is CMS pausing the review choice demonstration (the “Demonstration”) for home health services?
Yes. Effective March 29, 2020, certain claims for the RDC will be paused in Illinois, Ohio and Texas for the duration of the PHE for COVID-19. The previously scheduled begin dates for North Carolina and Florida (i.e., May 4, 2020) are postponed as well. MACs will continue to process claims submitted prior to the emergency period under normal processing claims. Claims filed on or after March 29, 2020 will not be subject to the review choices made by the home health agency (HHA) under the Demonstration. Instead, MACs will conduct post-payment review on claims subject to the Demonstration that were submitted and paid during the pause.
Further, HHAs will not receive additional documentation requests (ADRs) during the pause, and ADRs issued prior to the PHE will be released and processed as normal.
- The demonstration is currently scheduled to end on May 31, 2024. Given this pause, will CMS extend the Demonstration beyond that date?
No. CMS is not planning to extend the Demonstration. Should CMS decide to extend the Demonstration, it will provide proper public notice of the extension.
For any questions regarding the FAQs Sheet issued by CMS, please contact Jessica L. Gustafson, Esq. or Abby Pendleton, Esq. at (248) 996-8510 or by email at jgustafson@thehlp.com and apendleton@thehlp.com.