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COVID-19: After the Public Health Emergency Ends

The document provides an overview of policies and regulations related to the COVID-19 public health emergency, highlighting changes in vaccine administration, testing, workforce flexibilities, and telehealth services as the emergency ends. Key deadlines are outlined for the expiration of waivers and flexibilities, including changes to Medicare coverage and vaccine billing policies. The presentation emphasizes that while some regulations are phasing out, certain requirements for healthcare workers and vaccination protocols remain in place.

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© Health Catalyst. Confidential and Proprietary. COVID-19: After the Public Health Emergency Ends Ardith Campbell, COC, CPC
© Health Catalyst. Confidential and Proprietary. Disclaimer Statement This presentation was current at the time it was published or provided via the web and is designed to provide accurate and authoritative information regarding the subject matter covered. The information provided is only intended to be a general overview with the understanding that neither the presenter nor the event sponsor is engaged in rendering specific coding advice. It is not intended to take the place of either the written policies or regulations. We encourage participants to review the specific regulations and other interpretive materials, as necessary. All CPT® codes are trademarked by the American Medical Association (AMA) and all revenue codes are copyrighted by the American Hospital Association (AHA).
Agenda • Public Health Emergency (PHE) waivers and flexibilities overview and changes • COVID-19 vaccines, treatments, and therapies • COVID-19 testing and reporting • Workforce flexibilities • The Centers for Medicare & Medicaid Services (CMS) Hospitals Without Walls • Telehealth and remote services • Reducing administrative burden (Stark Law)
© Health Catalyst. Confidential and Proprietary. Reminders • Waivers and flexibilities were created to ease the acute phase of the pandemic — not to replace regulations permanently. • Most blanket waivers will terminate or have already phased out. • Your Medicare Administrative Contractor (MAC) is an available resource. • U.S. Food & Drug Administration (FDA) Emergency Use Authorizations (EUAs) function under a different declaration. • Policies for Medicare Advantage and commercial payers may differ.
© Health Catalyst. Confidential and Proprietary. Waivers & Flexibility Timeline - 2023 May 11, 2023: PHE, most blanket waivers — including scope of practice, and health and safety waivers — expire. OTC testing coverage ends. June 2023: SNF enforcement discretion allowing pharmacies to administer vaccines in SNF ends. December 31, 2023: Virtual supervision flexibility concludes.
© Health Catalyst. Confidential and Proprietary. Waivers & Flexibility Timeline - 2024 April 30, 2024: Certain nursing home and hospital reporting requirements discontinue. December 2024: Expect further reductions in nursing home and hospital reporting requirements. December 31, 2024: Most Medicare telehealth flexibility provisions and Extension of Acute Hospital of Care at Home ends.
© Health Catalyst. Confidential and Proprietary. COVID-19 Vaccines • The Centers for Medicare & Medicaid Services (CMS) won’t pay for any drug that you received for free. • CMS will pay approximately $40 for administering each dose of vaccines. • On January 1, following the conclusion of the EUA declaration, payment rates will follow the Part B preventive vaccines rate. • Additional payment of approximately $36 when vaccines are administered in patient's home. • Extends through 2023.
© Health Catalyst. Confidential and Proprietary. COVID-19 Vaccines – Exception for Skilled Nursing Facility (SNF) Waivers • During the pandemic, CMS enforcement discretion allowed Medicare-enrolled immunizers to bill directly and receive payment for vaccinating Medicare SNF residents. • Discretion continues through June 30, 2023. • Effective July 1, 2023, immunizers will no longer be allowed to bill Medicare directly for vaccines furnished to patients for a Medicare Part A-covered SNF stay. • SNF consolidated billing regulations to resume. • SNFs are to bill for all services furnished to patients in a Medicare-covered SNF stay.
© Health Catalyst. Confidential and Proprietary. Healthcare Worker Vaccination and Masking Requirements • Vaccine requirements remain unaltered per National Stakeholder Call on April 25, 2023. • Healthcare workers must be “fully vaccinated.” • Definition of “fully vaccinated” is evolving. • One dose of a bivalent vaccine meets the requirement. • Masking requirements must adhere to state & local guidelines: • In accordance with safety measures.
© Health Catalyst. Confidential and Proprietary. White House Announcement May 1, 2023 "Today, we are announcing that the Administration will end the COVID-19 vaccine requirements for Federal employees, Federal contractors, and international air travelers at the end of the day on May 11, the same day that the COVID-19 public health emergency ends. Additionally, HHS and DHS announced today that they will start the process to end their vaccination requirements for Head Start educators, CMS-certified healthcare facilities, and certain noncitizens at the land border. In the coming days, further details related to ending these requirements will be provided.” • Emphasis added.
© Health Catalyst. Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91300 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, diluent reconstituted, for intramuscular use. 0001A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, diluent reconstituted; first dose. 0002A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, diluent reconstituted; second dose. 0003A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, diluent reconstituted; third dose. 0004A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, diluent reconstituted; booster dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91301 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5 mL dosage, for intramuscular use. 0011A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5 mL dosage; first dose. 0012A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5 mL dosage; second dose. 0013A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5 mL dosage; third dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91305 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation, for intramuscular use. 0051A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation; first dose. 0052A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation; second dose. 0053A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation; third dose. 0054A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation; booster dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91306 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.25 mL dosage, for intramuscular use. 0064A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.25 mL dosage, booster dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91307 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, for intramuscular use. 0071A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; first dose. 0072A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; second dose. 0073A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; third dose. 0074A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; booster dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91308 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris- sucrose formulation, for intramuscular use. 0081A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; first dose. 0082A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; second dose. 0083A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; third dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91309 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA- LNP, spike protein, preservative free, 50 mcg/0.5 mL dosage, for intramuscular use. 0091A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.5 mL dosage; first dose, when administered to individuals 6 through 11 years. 0092A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.5 mL dosage; second dose, when administered to individuals 6 through 11 years. 0093A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.5 mL dosage; third dose, when administered to individuals 6 through 11 years. 0094A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.5 mL dosage; booster dose, when administered to individuals 6 through 11 years.
© Health Catalyst. Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91311 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 25 mcg/0.25 mL dosage, for intramuscular use. 0111A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 25 mcg/0.25 mL dosage; first dose. 0112A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 25 mcg/0.25 mL dosage; second dose. 0113A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 25 mcg/0.25 mL dosage; third dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Bivalent Vaccine Code Updates CPT® Code Description 91312 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation, for intramuscular use. 0121A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation, single dose. 0124A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation, additional dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Bivalent Vaccine Code Updates CPT® Code Description 91313 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 50 mcg/0.5 mL dosage, for intramuscular use. 0134A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 50 mcg/0.5 mL dosage, additional dose. 91316 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 10 mcg/0.2 mL dosage, for intramuscular use. 0164A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 10 mcg/0.2 mL dosage, additional dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Bivalent Vaccine Code Updates CPT® Code Description 91314 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 25 mcg/0.25 mL dosage, for intramuscular use. 0141A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 25 mcg/0.25 mL dosage, first dose. 0142A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 25 mcg/0.25 mL dosage, second dose. 0144A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 25 mcg/0.25 mL dosage, additional dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Bivalent Vaccine Code Updates CPT® Code Description 91315 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, for intramuscular use. 0151A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, first dose. 0154A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, additional dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Bivalent Vaccine Code Updates CPT® Code Description 91317 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA- LNP, bivalent spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, for intramuscular use. 0171A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, first dose. 0172A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, second dose. 0173A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, third dose. 0174A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, additional dose.
© Health Catalyst. Confidential and Proprietary. COVID-19 Monoclonal Antibody Therapy • Actemra® (tocilizumab) allowed for hospitalized adult patients with COVID-19: • On systemic corticosteroids. • Require supplemental oxygen. • Non-invasive or invasive mechanical ventilation. • Extracorporeal membrane oxygenation (ECMO). • Will be covered until January of the year following the year the EUA ends. • If EUAs are reinstated for other monoclonal antibodies, then will be covered similar to administration of other complex biologicals. • Pre-Exposure Prophylaxis (PEP) reimbursed under preventive vaccine benefit.
© Health Catalyst. Confidential and Proprietary. Other Treatments • COVID-19 Oral Antivirals have been procured by the U.S. Government (USG) and provided to pharmacies. • USG to continue this procurement process. • After procurement period, antivirals must be covered by Medicare Part D through 2024. • Veklury™ (remdesivir) wasn’t procured by the USG, so continues to be covered under Medicare Part B until EUA revoked. • The Over-the-Counter (OTC) COVID-19 test program will end at the end of the PHE.
© Health Catalyst. Confidential and Proprietary. Claim Submission Updates • When PHE ends, the following codes become obsolete: • Condition Code DR Disaster Related. • Modifier CR Catastrophe/Disaster Related. • If you’re in a different PHE, then condition code DR & modifier CR may be used.
© Health Catalyst. Confidential and Proprietary. Payment Updates - Hospital • Hospital inpatient stays will no longer have the New COVID-19 Treatment Add-on Payment (NCTAP) adjustment after 09/30/2023. • Hospital inpatient stays will no longer have the 20% Medicare Severity Diagnosis Related Grouping (MS-DRG) add-on. • Hospital outpatient claims will package drugs and treatments into the Comprehensive Ambulatory Payment Classification (C-APC) payment. • “On January 30, 2023, the Biden Administration announced its intent to end the national emergency and public health emergency declarations on May 11, 2023, related to the COVID-19 pandemic. Section 3710 of the CARES Act directs the Secretary to increase the weighting factor of the assigned Diagnosis-Related Group (DRG) by 20 percent for an individual diagnosed with COVID-19 discharged during the COVID-19 Public Health Emergency (PHE) period. Therefore, this 20 percent increase would not be applicable for IPPS discharges occurring on or after May 12, 2023.” • https://www.cms.gov/medicare/medicare-fee-for-service-payment/acuteinpatientpps
© Health Catalyst. Confidential and Proprietary. COVID-19 Diagnostic Testing and Reporting • Price transparency for COVID-19 testing will no longer be required. • Other price transparency laws and regulations may still apply. • All COVID-19 and related testing will require a physician or non-physician practitioner (NPP) order. • Current Procedural Terminology (CPT®) code 99211 Office or other outpatient visit for the evaluation and management of an established patient that may not require the presence of a physician or other qualified health care professional may be reported for COVID-19 specimen collection for new or established patients. • On May 12, provision reverses and must only use code for established patients. • Healthcare Common Procedure Coding System (HCPCS) code C9803 Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) coronavirus disease [COVID-19], any specimen source remains active. • Payment rate of approximately $25 when reimbursed separately. • Watch for updates in final rule.
© Health Catalyst. Confidential and Proprietary. Deleted Codes * No Replacement CPT/HCPCS Code Description G2023* Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]), any specimen source. G2024* Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) from an individual in a SNF or by a laboratory on behalf of a HHA, any specimen source. U0003 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique, making use of high throughput technologies as described by CMS-2020-01-R U0004 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC, making use of high throughput technologies as described by CMS-2020-01-R. U0005* Infectious agent detection by nucleic acid (DNA or RNA); Severe Acute Respiratory Syndrome Coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]), amplified probe technique, CDC or non-CDC, making use of high throughput technologies, completed within 2 calendar days from date of specimen collection (List separately in addition to either HCPCS code U0003 or U0004) as described by CMS-2020-01-R2.
© Health Catalyst. Confidential and Proprietary. COVID-19 Laboratory Tests CPT® Code Description 86318 Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single-step method (eg, reagent strip). 86328 Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single-step method (eg, reagent strip); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]). 86408 Neutralizing antibody, severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]); screen. 86409 Neutralizing antibody, severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]); titer. 86413 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) antibody, quantitative. 86769 Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]).
© Health Catalyst. Confidential and Proprietary. COVID-19 Laboratory Tests CPT® Code Description 87426 Infectious agent antigen detection by immunoassay technique (eg, enzyme immunoassay [EIA], enzyme-linked immunosorbent assay [ELISA], fluorescence immunoassay [FIA], immunochemiluminometric assay [IMCA]), qualitative or semiquantitative; severe acute respiratory syndrome coronavirus (eg, SARS-CoV, SARS-CoV-2 [COVID-19]). 87428 Infectious agent antigen detection by immunoassay technique (eg, enzyme immunoassay [EIA], enzyme-linked immunosorbent assay [ELISA], fluorescence immunoassay [FIA], immunochemiluminometric assay [IMCA]), qualitative or semiquantitative; severe acute respiratory syndrome coronavirus (eg, SARS-CoV, SARS-CoV-2 [COVID-19]) and influenza virus types A and B. 87631 Infectious agent detection by nucleic acid (DNA or RNA); respiratory virus (eg, adenovirus, influenza virus, coronavirus, metapneumovirus, parainfluenza virus, respiratory syncytial virus, rhinovirus), includes multiplex reverse transcription, when performed, and multiplex amplified probe technique, multiple types or subtypes, 3-5 targets. 87632 Infectious agent detection by nucleic acid (DNA or RNA); respiratory virus (eg, adenovirus, influenza virus, coronavirus, metapneumovirus, parainfluenza virus, respiratory syncytial virus, rhinovirus), includes multiplex reverse transcription, when performed, and multiplex amplified probe technique, multiple types or subtypes, 6-11 targets.
© Health Catalyst. Confidential and Proprietary. COVID-19 Laboratory Tests CPT® Code Description 87633 Infectious agent detection by nucleic acid (DNA or RNA); respiratory virus (eg, adenovirus, influenza virus, coronavirus, metapneumovirus, parainfluenza virus, respiratory syncytial virus, rhinovirus), includes multiplex reverse transcription, when performed, and multiplex amplified probe technique, multiple types or subtypes, 12-25 targets. 87635 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique. 87636 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) and influenza virus types A and B, multiplex amplified probe technique. 87637 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), influenza virus types A and B, and respiratory syncytial virus, multiplex amplified probe technique.
© Health Catalyst. Confidential and Proprietary. COVID-19 Laboratory Tests CPT® Code Description 87811 Infectious agent antigen detection by immunoassay with direct optical (ie, visual) observation; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]). 87913 Infectious agent genotype analysis by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]), mutation identification in targeted region(s). 0202U Infectious disease (bacterial or viral respiratory tract infection), pathogen-specific nucleic acid (DNA or RNA), 22 targets including severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), qualitative RT-PCR, nasopharyngeal swab, each pathogen reported as detected or not detected. 0223U Infectious disease (bacterial or viral respiratory tract infection), pathogen-specific nucleic acid (DNA or RNA), 22 targets including severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), qualitative RT-PCR, nasopharyngeal swab, each pathogen reported as detected or not detected. 0224U Antibody, severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), includes titer(s), when performed.
© Health Catalyst. Confidential and Proprietary. COVID-19 Laboratory Tests CPT® Code Description 0225U Infectious disease (bacterial or viral respiratory tract infection) pathogen-specific DNA and RNA, 21 targets, including severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), amplified probe technique, including multiplex reverse transcription for RNA targets, each analyte reported as detected or not detected. 0226U Surrogate viral neutralization test (sVNT), severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (Coronavirus disease [COVID-19]), ELISA, plasma, serum. 0240U Infectious disease (viral respiratory tract infection), pathogen-specific RNA, 3 targets (severe acute respiratory syndrome coronavirus 2 [SARS-CoV-2], influenza A, influenza B), upper respiratory specimen, each pathogen reported as detected or not detected. 0241U Infectious disease (viral respiratory tract infection), pathogen-specific RNA, 4 targets (severe acute respiratory syndrome coronavirus 2 [SARS-CoV-2], influenza A, influenza B, respiratory syncytial virus [RSV]), upper respiratory specimen, each pathogen reported as detected or not detected.
© Health Catalyst. Confidential and Proprietary. COVID-19 Diagnostic Testing and Reporting • Diagnosis coding guidance update effective October 1, 2023. • AHA Coding Clinic® for ICD-10, 2023Q1, Announcement • “As a result of the COVID-19 Public Health Emergency ending on May 11, 2023, the FY24 ICD-10-CM Official Guidelines for Coding and Reporting will be revised to state that code Z11.52, Encounter for screening for COVID-19, should be assigned for encounters for screening for COVID-19 infection. This guideline change will become effective October 1, 2023.”
© Health Catalyst. Confidential and Proprietary. Workforce Flexibilities
© Health Catalyst. Confidential and Proprietary. Workforce Flexibilities - Professional • Direct supervision, including “virtual presence,” ends on December 31, 2023. • Non-Surgical Extended Duration Therapeutic Services (NSDETS), as general- level regulations, were made permanent. • Obtaining beneficiary consent, acquired by auxiliary personnel not employed by the billing practitioner, ends December 31, 2023. • Nonphysician practitioner (NPP) supervision of diagnostic tests defaults to state law and licensure made permanent. • Flexibility allowing pharmacists, other health care professionals to order lab tests expires at the end of the PHE. • Rules stipulating that hospitalized patients do not need to be under the care of a physician ends immediately with the termination of the PHE.
© Health Catalyst. Confidential and Proprietary. Workforce Flexibilities - Professional • Practitioner locations: • Must be licensed in the state where they practice; defaults to state law. • Services provided outside their state of enrollment also default to state law. • Reporting home address for telehealth services – may use currently enrolled location through the end of 2023. • Care Compare can suppress the home address. • National Coverage Determinations (NCDs) and Local Coverage Determinations (LCDs) flexibilities ending at the termination of the PHE. • Requiring specific practitioner type. • Clinical indications in LCDs for therapeutic continuous glucose monitors. • Substitute Billing Arrangements (Locum Tenens) returns to pre-COVID regulations 60 days after the end of the PHE – July 10.
© Health Catalyst. Confidential and Proprietary. Workforce Flexibilities – Teaching Physicians • Only teaching physicians in residency training sites located outside of a metropolitan statistical area (MSA) may use audio/video real-time communication technology to meet the “present for key portion” requirement. • Teaching physicians can report levels 4-5 of an evaluation and management (E/M) service when the physician is physically present for the key portion of the service. • Does not apply to surgical, high-risk, interventional, other complex procedures, services performed through an endoscope, and anesthesia services. • Resident moonlighting – allows services not related to a resident’s approved graduate medical education (GME) program to be separately billable. • Outpatient (OP) department. • Emergency department (ED). • Inpatient services.
© Health Catalyst. Confidential and Proprietary. • May no longer count resident time at alternate locations. • This includes their own home or a patient’s home. • A teaching hospital that sends residents to other hospitals cannot claim those residents in its Indirect Medical Education (IME) and Direct Graduate Medical Education (DGME) Full Time Equivalent (FTE) resident counts. • The presence of residents in non-teaching hospitals will trigger the establishment of IME and DGME FTE resident caps at the non-teaching hospital. • Temporary increase in beds. • Any added beds will be considered in determining the IME payments. • Regarding Inpatient psychiatric facilities (IPFs) and Inpatient Rehabilitation Facilities (IRFs), any change to the average daily census will be considered in determining teaching status adjustment payments. Workforce Flexibilities – Teaching Physicians
© Health Catalyst. Confidential and Proprietary. Workforce – Hospital, Teaching Hospitals • Waivers are ending at the conclusion of the PHE. • Sterile compounding allowance of face mask to be removed and retained in the compounding area, to be reused during the same work shift in the compounding area. • Physicians whose privileges would have expired were allowed to continue practicing. • New physicians allowed to practice in a hospital before full medical staff/governing body review and approval. • Certified Registered Nurse Anesthetist (CRNA) physician supervision waiver. • Hospital written designation of the personnel qualified to perform specific respiratory care procedures and amount of supervision. • Critical Access Hospital (CAH) deferring all licensure, certification, registration, and minimum qualifications.
© Health Catalyst. Confidential and Proprietary. CMS Hospitals Without Walls
© Health Catalyst. Confidential and Proprietary. Acute Hospital Care at Home • The main Hospitals Without Walls flexibilities are ending. • Acute Hospital Care at Home expands on the Hospital Without Walls initiative. • Consolidated Appropriations Act, 2023 (CAA) expands program through 2024. • Must apply to participate.
© Health Catalyst. Confidential and Proprietary. Hospitals Without Walls - Ending • The flexibilities are ending because CMS doesn’t have the authority to change the regulations. • Teaching Hospital Fact Sheet mirrors the Hospital fact sheet for this section. • Temporary expansion sites. • Providers temporarily enrolled as a hospital: • Ambulatory surgical centers (ASCs): • Must submit notification of intent to convert back to ASC status. • Must meet hospital certification standards to become a hospital. • Independent, free standing, emergency departments (IFEDs). • Off-Site Patient Screening.
© Health Catalyst. Confidential and Proprietary. Hospitals Without Walls - Ending • Paperwork requirements: • Timeframe for providing a copy of a medical record. • Written policies & procedures on visitation of patients who are in COVID-19 isolation and quarantine processes. • Seclusion and restraint of patients. • Physical Environment requirements: • Facility and non-facility space not normally used for patient care. • Specific Life Safety Code: • Alcohol-Based Hand-Rub dispenser waiver of prescriptive and storage requirements. • Temporary construction of walls and barriers between patients. • Use of Provider-Based Departments (PBDs) as temporary expansion sites.
© Health Catalyst. Confidential and Proprietary. Hospitals Without Walls - Ending • Supporting hospitals to more effectively respond to COVID-19 PHE. • Temporary extraordinary circumstances relocation exception policy for on-campus PBDs and excepted off-campus PBDs. • Streamlining process for relocating PBDs to seek the exception so providers can see patients and bill for services. • Allowing PBDs to relocate to more than one PBD location, or partially relocate, while remaining in the original location and receiving the full Outpatient Prospective Payment System (OPPS) amount. • Patient’s home. • Temporarily relocated PBDs that are permanently relocated will be considered new off- campus PBD. • Use modifier PN Non-excepted service provided at an off-campus, outpatient, provider-based department of a hospital. • Temporarily relocated excepted off-campus locations that permanently located need to follow standard extraordinary circumstances relocation process.
© Health Catalyst. Confidential and Proprietary. Hospitals Without Walls - Ending • Hospital-Only Remote Outpatient Therapy and Education Services provided in the patient’s home as if they were furnished in-person. • Partial Hospitalization Program (PHP) services provided to a patient in their home. • Expanded ability for hospitals to offer long-term care services (swing beds) for patients who do not require acute care but do meet the Skilled Nursing Facility (SNF) level of care criteria. • Critical Access Hospital (CAH) status and location requirements relaxation. • Located in a rural area, or area being treated as rural. • Surge site locations. • Establish off-campus and co-location requirements.
© Health Catalyst. Confidential and Proprietary. Hospitals Without Walls - Ending • Sole Community Hospitals (SCHs) eligibility requirements. • Market share and bed requirements. • Medicare-Dependent, Small Rural Hospitals (MDHs) requirements. • 100 or fewer beds. • 60% of inpatient days or discharges attributable to Medicare Part A. • Housing acute care patients in distinct part units. • Care for excluded inpatient psychiatric unit patients in the acute care unit of a hospital. • Care for excluded inpatient rehabilitation unit patients in the acute care unit of a hospital. • Inpatient rehabilitation facilities and the 60% rule. • All inpatients will be included in the inpatient population for purposes of calculating the thresholds.
© Health Catalyst. Confidential and Proprietary. Hospitals Without Walls - Ending • Hospital-Only clinical staff in-person services where the patient’s home was considered to be a PBD for the purpose of receiving outpatient services. • Services required to be furnished by a health professional, such as infusion or wound care. • Reported as if performed at the hospital. • Require an order by the physician or NPP. • Require supervision, which may be through audio/visual communication.
© Health Catalyst. Confidential and Proprietary. SNF-Specific Issues • Qualifying prior hospitalization stay: • Effective May 12, SNF patient admissions revert to pre-PHE requirements. • Patients admitted during PHE do not require the qualifying hospital stay until they’re discharged. • Patient may have a three-day break without issue. • The 30-day transfer policy doesn’t apply to patients who do not have a qualifying hospital stay. • Patient COVID-19 testing requirement technically ends with the PHE – BUT: • May continue as part of the national safety standard. • May follow infection control practices. • Same guidance applies to masking and handwashing.
© Health Catalyst. Confidential and Proprietary. Telehealth and Remote Services
© Health Catalyst. Confidential and Proprietary. Telehealth • Services furnished via telecommunication technology provided remotely to a patient who is a patient in the hospital, which may include the patient’s home if the home is declared a PBD. • The Consolidated Appropriations Act, 2023 (CAA) applies to professional services. • Hospital-Only remote outpatient therapy and education services. • Partial Hospitalization Program (PHP) services. • Telemedicine services provided to the hospital’s patients through an agreement with an off-site hospital. Facilities - Ending
© Health Catalyst. Confidential and Proprietary. Telehealth • For PBDs, what can be reported when the physician or NPP provides telehealth to a patient at home? • The facility isn’t able to report anything for this service. • What about Q3014 or G0463? • The facility is not able to report either Q3014 or G0463 when the provider is in the facility and the patient is home. • HCPCS Q3014 Telehealth originating site facility fee may be reported when facility meets requirements as an originating site. • What about hospital-employed physical therapists (PTs), occupational therapists (OTs) or speech language pathologists (SLPs)? • They can’t provide telehealth services. • They can only provide services to patients physically within the hospital. Facility – Questions & Answers
© Health Catalyst. Confidential and Proprietary. Telehealth • Medicare beneficiaries receiving telehealth services wherever they are located. • Extended through December 31, 2024. • Audio-only services in limited circumstances. • Extended through December 31, 2024. • Expanded list of approved telehealth services through 2023. • Watch for updates in the 2024 Medicare Physician Fee Schedule (MPFS) final rule. • Providers expanded to those who are eligible to bill Medicare for their professional services. • Extended through December 31, 2024. • No geographic restrictions, except for teaching physicians. Professional
© Health Catalyst. Confidential and Proprietary. Telehealth • Continue with current reporting through December 31, 2023. • Place of service for 2024: • 02 Telehealth Provided Other than in Patient’s Home. • 10 Telehealth Provided in Patient’s Home. • Audio-only allowed in limited circumstances for diagnosis, evaluation, or treatment of a mental health or substance use disorder – ruling made permanent. • CPT® codes 99441-99443 will be allowed through 2024. • CMS advises providers to monitor the rule-making process. Professional
© Health Catalyst. Confidential and Proprietary. Telehealth • If the provider is doing telehealth at home, do they need to update their enrollment information? • Generally, yes. The address is only viewable through Care Compare. • QPP@cms.hhs.gov Professional – Questions and Answers
© Health Catalyst. Confidential and Proprietary. Remote Evaluations, Virtual Check-Ins & E-Visits • Providers who bill Medicare for their professional services may provide e-visits: • Non-face-to-face communications, such as using an on-line portal. • Physicians/NPPs may use 99421-99423. • Licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, speech language pathologists may use 98970-98972. • Policy made permanent in the 2021 MPFS Final Rule. • Clinicians must have an established relationship prior to providing remote physiologic monitoring (RPM) services. • PHE allowed 99453-99454 to be reported when 2 days of data collected in certain scenarios. • After PHE, returns to a minimum of 16 days of data collection to report. Professional
© Health Catalyst. Confidential and Proprietary. Telehealth/Telemedicine • Removal of frequency limitations on certain telehealth services ends with PHE. • Subsequent inpatient visits could be telehealth once every 3 days. • Subsequent SNF telehealth visit once every 14 days. • Critical care consultation codes beyond the once per day limitation. • Patients with End Stage Renal Disease (ESRD) must have a face-to-face visit monthly and telehealth visits will no longer replace the face-to-face visit. • Restoration of language within National Coverage Determination (NCD) or Local Coverage Determination (LCD) in-person, face-to-face visits for evaluation or assessment no longer to be provided via telehealth. • Any NCD/LCD requiring a specific practitioner type or specialty reinstated. • Virtual check-ins only for established patients, and no longer available for new patients. Professional
© Health Catalyst. Confidential and Proprietary. Telehealth • In-person delivery of MDPP services suspended through December 31, 2023. • Translation: telehealth delivery of services through 2023 allowed. • Original guidance stated: “through the end of the PHE.” • Allows for alternative to in-person weight measurement. • Eliminates the maximum number of virtual services. • Published in Federal Register on May 2, 2023. Medicare Diabetes Prevention Program (MDPP) Expanded Model Suppliers
© Health Catalyst. Confidential and Proprietary. Reducing Administrative Burden (Stark Law)
© Health Catalyst. Confidential and Proprietary. Reducing Administrative Burden – Waivers Ending • Stark Law waivers are ending. • Physician self-referrals, etc. • Must immediately comply with all provisions of the Stark Law. • Waivers also ending. • Pay above or below fair market value for physician’s services, rent equipment, or purchase items or services. • Financial support such as personal loans without charging interest. • Benefits such as multiple daily meals, personal laundry service, and free childcare. • Offering items or services that would exceed the non-monetary compensation cap. • Physician-owned hospitals temporarily increasing the number of licensed beds, operating rooms, and procedure rooms. • Furnishing magnetic resonance imaging (MRI) or computed tomography (CT) scans or laboratory services from locations like mobile vans in parking lots.
© Health Catalyst. Confidential and Proprietary. Reducing Administrative Burden – Waivers Ending • Verbal orders where authentication may occur later than 48 hours. • Limited discharge planning for hospitals and CAHs to not use quality measures and data to select discharge entity. • Modified discharge planning where the patient may not receive a comprehensive list of nursing homes in the geographic area. • Completion of medical records within 30 days or “promptly” for CAHs. • Utilization review Conditions of Participation (CoP) requiring a utilization review plan and committee. • Quality assessment and performance improvement (QAPI) program scope of the program and setting priorities for the performance improvement activities. • Current therapeutic diet manual approved by dietitian and medical staff available did not need to be maintained during the PHE. • Delivery of advance directive policies to large number of patients.
© Health Catalyst. Confidential and Proprietary. Reducing Administrative Burden • Inpatient Prospective Payment System (IPPS) Occupational Mix Survey collection is expected. • Medicare Geographic Classification applications must be submitted by September 1 of the year prior to the fiscal year (FY) 2023 or 2024. • Nursing services returning. • Develop and keep a nursing care plan for each patient. • Policies & procedures in place establishing which outpatient departments are not required to have a registered nurse present. • Surge facilities did not need to have written policies and procedures. • Surge facilities did not need to have emergency preparedness policies and procedures. • Signature requirements as proof of delivery for durable medical equipment (DME) items.
© Health Catalyst. Confidential and Proprietary. Reducing Administrative Burden • Hospital Value-Based Purchasing (VBP) program’s Extraordinary Circumstances Exceptions (ECE): • CMS will review each on a case-by-case basis. • Will no longer consider ECE for COVID-19 after the PHE. • If you need an extension for filing your cost report, submit a request to your MAC. • Hotlines for provider enrollment will be shut down. • Continue to report data for COVID-19 and other respiratory illnesses through April 30, 2024.
© Health Catalyst. Confidential and Proprietary. Questions? Q&A Document can be found on Healthcatalyst.com under Resources/Webinars
© Health Catalyst. Confidential and Proprietary. Resources Coronavirus Waivers & Flexibilities: https://www.cms.gov/coronavirus-waivers COVID-19 Vaccines and Monoclonal Antibodies Reimbursement: https://www.cms.gov/medicare/medicare-part-b-drug-average-sales-price/covid-19-vaccines-and- monoclonal-antibodies National Stakeholder Call – 04/25/2023: https://www.cms.gov/outreach-education/partner-resources/cms-national-stakeholder-calls Acute Hospital Care At Home: https://qualitynet.cms.gov/acute-hospital-care-at-home
© Health Catalyst. Confidential and Proprietary. Resources, cont. CPT® COVID-19 Vaccine and Immunization Codes (contains Appendix Q): https://www.ama-assn.org/practice-management/cpt/covid-19-cpt-vaccine-and- immunization-codes The White House Release: https://www.whitehouse.gov/briefing-room/statements-releases/2023/05/01/the-biden- administration-will-end-covid-19-vaccination-requirements-for-federal-employees- contractors-international-travelers-head-start-educators-and-cms-certified- facilities/#:~:text=Today%2C%20we%20are%20announcing%20that,19%20public%20health %20emergency%20ends.

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COVID-19: After the Public Health Emergency Ends

  • 1.
    © Health Catalyst.Confidential and Proprietary. COVID-19: After the Public Health Emergency Ends Ardith Campbell, COC, CPC
  • 2.
    © Health Catalyst.Confidential and Proprietary. Disclaimer Statement This presentation was current at the time it was published or provided via the web and is designed to provide accurate and authoritative information regarding the subject matter covered. The information provided is only intended to be a general overview with the understanding that neither the presenter nor the event sponsor is engaged in rendering specific coding advice. It is not intended to take the place of either the written policies or regulations. We encourage participants to review the specific regulations and other interpretive materials, as necessary. All CPT® codes are trademarked by the American Medical Association (AMA) and all revenue codes are copyrighted by the American Hospital Association (AHA).
  • 3.
    Agenda • Public HealthEmergency (PHE) waivers and flexibilities overview and changes • COVID-19 vaccines, treatments, and therapies • COVID-19 testing and reporting • Workforce flexibilities • The Centers for Medicare & Medicaid Services (CMS) Hospitals Without Walls • Telehealth and remote services • Reducing administrative burden (Stark Law)
  • 4.
    © Health Catalyst.Confidential and Proprietary. Reminders • Waivers and flexibilities were created to ease the acute phase of the pandemic — not to replace regulations permanently. • Most blanket waivers will terminate or have already phased out. • Your Medicare Administrative Contractor (MAC) is an available resource. • U.S. Food & Drug Administration (FDA) Emergency Use Authorizations (EUAs) function under a different declaration. • Policies for Medicare Advantage and commercial payers may differ.
  • 5.
    © Health Catalyst.Confidential and Proprietary. Waivers & Flexibility Timeline - 2023 May 11, 2023: PHE, most blanket waivers — including scope of practice, and health and safety waivers — expire. OTC testing coverage ends. June 2023: SNF enforcement discretion allowing pharmacies to administer vaccines in SNF ends. December 31, 2023: Virtual supervision flexibility concludes.
  • 6.
    © Health Catalyst.Confidential and Proprietary. Waivers & Flexibility Timeline - 2024 April 30, 2024: Certain nursing home and hospital reporting requirements discontinue. December 2024: Expect further reductions in nursing home and hospital reporting requirements. December 31, 2024: Most Medicare telehealth flexibility provisions and Extension of Acute Hospital of Care at Home ends.
  • 7.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Vaccines • The Centers for Medicare & Medicaid Services (CMS) won’t pay for any drug that you received for free. • CMS will pay approximately $40 for administering each dose of vaccines. • On January 1, following the conclusion of the EUA declaration, payment rates will follow the Part B preventive vaccines rate. • Additional payment of approximately $36 when vaccines are administered in patient's home. • Extends through 2023.
  • 8.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Vaccines – Exception for Skilled Nursing Facility (SNF) Waivers • During the pandemic, CMS enforcement discretion allowed Medicare-enrolled immunizers to bill directly and receive payment for vaccinating Medicare SNF residents. • Discretion continues through June 30, 2023. • Effective July 1, 2023, immunizers will no longer be allowed to bill Medicare directly for vaccines furnished to patients for a Medicare Part A-covered SNF stay. • SNF consolidated billing regulations to resume. • SNFs are to bill for all services furnished to patients in a Medicare-covered SNF stay.
  • 9.
    © Health Catalyst.Confidential and Proprietary. Healthcare Worker Vaccination and Masking Requirements • Vaccine requirements remain unaltered per National Stakeholder Call on April 25, 2023. • Healthcare workers must be “fully vaccinated.” • Definition of “fully vaccinated” is evolving. • One dose of a bivalent vaccine meets the requirement. • Masking requirements must adhere to state & local guidelines: • In accordance with safety measures.
  • 10.
    © Health Catalyst.Confidential and Proprietary. White House Announcement May 1, 2023 "Today, we are announcing that the Administration will end the COVID-19 vaccine requirements for Federal employees, Federal contractors, and international air travelers at the end of the day on May 11, the same day that the COVID-19 public health emergency ends. Additionally, HHS and DHS announced today that they will start the process to end their vaccination requirements for Head Start educators, CMS-certified healthcare facilities, and certain noncitizens at the land border. In the coming days, further details related to ending these requirements will be provided.” • Emphasis added.
  • 11.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91300 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, diluent reconstituted, for intramuscular use. 0001A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, diluent reconstituted; first dose. 0002A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, diluent reconstituted; second dose. 0003A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, diluent reconstituted; third dose. 0004A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, diluent reconstituted; booster dose.
  • 12.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91301 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5 mL dosage, for intramuscular use. 0011A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5 mL dosage; first dose. 0012A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5 mL dosage; second dose. 0013A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5 mL dosage; third dose.
  • 13.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91305 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation, for intramuscular use. 0051A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation; first dose. 0052A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation; second dose. 0053A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation; third dose. 0054A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation; booster dose.
  • 14.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91306 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.25 mL dosage, for intramuscular use. 0064A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.25 mL dosage, booster dose.
  • 15.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91307 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, for intramuscular use. 0071A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; first dose. 0072A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; second dose. 0073A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; third dose. 0074A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; booster dose.
  • 16.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91308 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris- sucrose formulation, for intramuscular use. 0081A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; first dose. 0082A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; second dose. 0083A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation; third dose.
  • 17.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91309 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA- LNP, spike protein, preservative free, 50 mcg/0.5 mL dosage, for intramuscular use. 0091A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.5 mL dosage; first dose, when administered to individuals 6 through 11 years. 0092A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.5 mL dosage; second dose, when administered to individuals 6 through 11 years. 0093A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.5 mL dosage; third dose, when administered to individuals 6 through 11 years. 0094A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 50 mcg/0.5 mL dosage; booster dose, when administered to individuals 6 through 11 years.
  • 18.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Vaccines No Longer Authorized – CPT® Codes CPT® Code Description 91311 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 25 mcg/0.25 mL dosage, for intramuscular use. 0111A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 25 mcg/0.25 mL dosage; first dose. 0112A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 25 mcg/0.25 mL dosage; second dose. 0113A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 25 mcg/0.25 mL dosage; third dose.
  • 19.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Bivalent Vaccine Code Updates CPT® Code Description 91312 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation, for intramuscular use. 0121A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation, single dose. 0124A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 30 mcg/0.3 mL dosage, tris-sucrose formulation, additional dose.
  • 20.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Bivalent Vaccine Code Updates CPT® Code Description 91313 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 50 mcg/0.5 mL dosage, for intramuscular use. 0134A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 50 mcg/0.5 mL dosage, additional dose. 91316 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 10 mcg/0.2 mL dosage, for intramuscular use. 0164A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 10 mcg/0.2 mL dosage, additional dose.
  • 21.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Bivalent Vaccine Code Updates CPT® Code Description 91314 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 25 mcg/0.25 mL dosage, for intramuscular use. 0141A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 25 mcg/0.25 mL dosage, first dose. 0142A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 25 mcg/0.25 mL dosage, second dose. 0144A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, bivalent, preservative free, 25 mcg/0.25 mL dosage, additional dose.
  • 22.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Bivalent Vaccine Code Updates CPT® Code Description 91315 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, for intramuscular use. 0151A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, first dose. 0154A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 10 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, additional dose.
  • 23.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Bivalent Vaccine Code Updates CPT® Code Description 91317 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA- LNP, bivalent spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, for intramuscular use. 0171A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, first dose. 0172A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, second dose. 0173A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, third dose. 0174A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (coronavirus disease [COVID-19]) vaccine, mRNA-LNP, bivalent spike protein, preservative free, 3 mcg/0.2 mL dosage, diluent reconstituted, tris-sucrose formulation, additional dose.
  • 24.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Monoclonal Antibody Therapy • Actemra® (tocilizumab) allowed for hospitalized adult patients with COVID-19: • On systemic corticosteroids. • Require supplemental oxygen. • Non-invasive or invasive mechanical ventilation. • Extracorporeal membrane oxygenation (ECMO). • Will be covered until January of the year following the year the EUA ends. • If EUAs are reinstated for other monoclonal antibodies, then will be covered similar to administration of other complex biologicals. • Pre-Exposure Prophylaxis (PEP) reimbursed under preventive vaccine benefit.
  • 25.
    © Health Catalyst.Confidential and Proprietary. Other Treatments • COVID-19 Oral Antivirals have been procured by the U.S. Government (USG) and provided to pharmacies. • USG to continue this procurement process. • After procurement period, antivirals must be covered by Medicare Part D through 2024. • Veklury™ (remdesivir) wasn’t procured by the USG, so continues to be covered under Medicare Part B until EUA revoked. • The Over-the-Counter (OTC) COVID-19 test program will end at the end of the PHE.
  • 26.
    © Health Catalyst.Confidential and Proprietary. Claim Submission Updates • When PHE ends, the following codes become obsolete: • Condition Code DR Disaster Related. • Modifier CR Catastrophe/Disaster Related. • If you’re in a different PHE, then condition code DR & modifier CR may be used.
  • 27.
    © Health Catalyst.Confidential and Proprietary. Payment Updates - Hospital • Hospital inpatient stays will no longer have the New COVID-19 Treatment Add-on Payment (NCTAP) adjustment after 09/30/2023. • Hospital inpatient stays will no longer have the 20% Medicare Severity Diagnosis Related Grouping (MS-DRG) add-on. • Hospital outpatient claims will package drugs and treatments into the Comprehensive Ambulatory Payment Classification (C-APC) payment. • “On January 30, 2023, the Biden Administration announced its intent to end the national emergency and public health emergency declarations on May 11, 2023, related to the COVID-19 pandemic. Section 3710 of the CARES Act directs the Secretary to increase the weighting factor of the assigned Diagnosis-Related Group (DRG) by 20 percent for an individual diagnosed with COVID-19 discharged during the COVID-19 Public Health Emergency (PHE) period. Therefore, this 20 percent increase would not be applicable for IPPS discharges occurring on or after May 12, 2023.” • https://www.cms.gov/medicare/medicare-fee-for-service-payment/acuteinpatientpps
  • 28.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Diagnostic Testing and Reporting • Price transparency for COVID-19 testing will no longer be required. • Other price transparency laws and regulations may still apply. • All COVID-19 and related testing will require a physician or non-physician practitioner (NPP) order. • Current Procedural Terminology (CPT®) code 99211 Office or other outpatient visit for the evaluation and management of an established patient that may not require the presence of a physician or other qualified health care professional may be reported for COVID-19 specimen collection for new or established patients. • On May 12, provision reverses and must only use code for established patients. • Healthcare Common Procedure Coding System (HCPCS) code C9803 Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) coronavirus disease [COVID-19], any specimen source remains active. • Payment rate of approximately $25 when reimbursed separately. • Watch for updates in final rule.
  • 29.
    © Health Catalyst.Confidential and Proprietary. Deleted Codes * No Replacement CPT/HCPCS Code Description G2023* Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]), any specimen source. G2024* Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) from an individual in a SNF or by a laboratory on behalf of a HHA, any specimen source. U0003 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique, making use of high throughput technologies as described by CMS-2020-01-R U0004 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC, making use of high throughput technologies as described by CMS-2020-01-R. U0005* Infectious agent detection by nucleic acid (DNA or RNA); Severe Acute Respiratory Syndrome Coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]), amplified probe technique, CDC or non-CDC, making use of high throughput technologies, completed within 2 calendar days from date of specimen collection (List separately in addition to either HCPCS code U0003 or U0004) as described by CMS-2020-01-R2.
  • 30.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Laboratory Tests CPT® Code Description 86318 Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single-step method (eg, reagent strip). 86328 Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single-step method (eg, reagent strip); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]). 86408 Neutralizing antibody, severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]); screen. 86409 Neutralizing antibody, severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]); titer. 86413 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) antibody, quantitative. 86769 Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]).
  • 31.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Laboratory Tests CPT® Code Description 87426 Infectious agent antigen detection by immunoassay technique (eg, enzyme immunoassay [EIA], enzyme-linked immunosorbent assay [ELISA], fluorescence immunoassay [FIA], immunochemiluminometric assay [IMCA]), qualitative or semiquantitative; severe acute respiratory syndrome coronavirus (eg, SARS-CoV, SARS-CoV-2 [COVID-19]). 87428 Infectious agent antigen detection by immunoassay technique (eg, enzyme immunoassay [EIA], enzyme-linked immunosorbent assay [ELISA], fluorescence immunoassay [FIA], immunochemiluminometric assay [IMCA]), qualitative or semiquantitative; severe acute respiratory syndrome coronavirus (eg, SARS-CoV, SARS-CoV-2 [COVID-19]) and influenza virus types A and B. 87631 Infectious agent detection by nucleic acid (DNA or RNA); respiratory virus (eg, adenovirus, influenza virus, coronavirus, metapneumovirus, parainfluenza virus, respiratory syncytial virus, rhinovirus), includes multiplex reverse transcription, when performed, and multiplex amplified probe technique, multiple types or subtypes, 3-5 targets. 87632 Infectious agent detection by nucleic acid (DNA or RNA); respiratory virus (eg, adenovirus, influenza virus, coronavirus, metapneumovirus, parainfluenza virus, respiratory syncytial virus, rhinovirus), includes multiplex reverse transcription, when performed, and multiplex amplified probe technique, multiple types or subtypes, 6-11 targets.
  • 32.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Laboratory Tests CPT® Code Description 87633 Infectious agent detection by nucleic acid (DNA or RNA); respiratory virus (eg, adenovirus, influenza virus, coronavirus, metapneumovirus, parainfluenza virus, respiratory syncytial virus, rhinovirus), includes multiplex reverse transcription, when performed, and multiplex amplified probe technique, multiple types or subtypes, 12-25 targets. 87635 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique. 87636 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) and influenza virus types A and B, multiplex amplified probe technique. 87637 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), influenza virus types A and B, and respiratory syncytial virus, multiplex amplified probe technique.
  • 33.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Laboratory Tests CPT® Code Description 87811 Infectious agent antigen detection by immunoassay with direct optical (ie, visual) observation; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]). 87913 Infectious agent genotype analysis by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]), mutation identification in targeted region(s). 0202U Infectious disease (bacterial or viral respiratory tract infection), pathogen-specific nucleic acid (DNA or RNA), 22 targets including severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), qualitative RT-PCR, nasopharyngeal swab, each pathogen reported as detected or not detected. 0223U Infectious disease (bacterial or viral respiratory tract infection), pathogen-specific nucleic acid (DNA or RNA), 22 targets including severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), qualitative RT-PCR, nasopharyngeal swab, each pathogen reported as detected or not detected. 0224U Antibody, severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), includes titer(s), when performed.
  • 34.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Laboratory Tests CPT® Code Description 0225U Infectious disease (bacterial or viral respiratory tract infection) pathogen-specific DNA and RNA, 21 targets, including severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), amplified probe technique, including multiplex reverse transcription for RNA targets, each analyte reported as detected or not detected. 0226U Surrogate viral neutralization test (sVNT), severe acute respiratory syndrome coronavirus 2 (SARS- CoV-2) (Coronavirus disease [COVID-19]), ELISA, plasma, serum. 0240U Infectious disease (viral respiratory tract infection), pathogen-specific RNA, 3 targets (severe acute respiratory syndrome coronavirus 2 [SARS-CoV-2], influenza A, influenza B), upper respiratory specimen, each pathogen reported as detected or not detected. 0241U Infectious disease (viral respiratory tract infection), pathogen-specific RNA, 4 targets (severe acute respiratory syndrome coronavirus 2 [SARS-CoV-2], influenza A, influenza B, respiratory syncytial virus [RSV]), upper respiratory specimen, each pathogen reported as detected or not detected.
  • 35.
    © Health Catalyst.Confidential and Proprietary. COVID-19 Diagnostic Testing and Reporting • Diagnosis coding guidance update effective October 1, 2023. • AHA Coding Clinic® for ICD-10, 2023Q1, Announcement • “As a result of the COVID-19 Public Health Emergency ending on May 11, 2023, the FY24 ICD-10-CM Official Guidelines for Coding and Reporting will be revised to state that code Z11.52, Encounter for screening for COVID-19, should be assigned for encounters for screening for COVID-19 infection. This guideline change will become effective October 1, 2023.”
  • 36.
    © Health Catalyst.Confidential and Proprietary. Workforce Flexibilities
  • 37.
    © Health Catalyst.Confidential and Proprietary. Workforce Flexibilities - Professional • Direct supervision, including “virtual presence,” ends on December 31, 2023. • Non-Surgical Extended Duration Therapeutic Services (NSDETS), as general- level regulations, were made permanent. • Obtaining beneficiary consent, acquired by auxiliary personnel not employed by the billing practitioner, ends December 31, 2023. • Nonphysician practitioner (NPP) supervision of diagnostic tests defaults to state law and licensure made permanent. • Flexibility allowing pharmacists, other health care professionals to order lab tests expires at the end of the PHE. • Rules stipulating that hospitalized patients do not need to be under the care of a physician ends immediately with the termination of the PHE.
  • 38.
    © Health Catalyst.Confidential and Proprietary. Workforce Flexibilities - Professional • Practitioner locations: • Must be licensed in the state where they practice; defaults to state law. • Services provided outside their state of enrollment also default to state law. • Reporting home address for telehealth services – may use currently enrolled location through the end of 2023. • Care Compare can suppress the home address. • National Coverage Determinations (NCDs) and Local Coverage Determinations (LCDs) flexibilities ending at the termination of the PHE. • Requiring specific practitioner type. • Clinical indications in LCDs for therapeutic continuous glucose monitors. • Substitute Billing Arrangements (Locum Tenens) returns to pre-COVID regulations 60 days after the end of the PHE – July 10.
  • 39.
    © Health Catalyst.Confidential and Proprietary. Workforce Flexibilities – Teaching Physicians • Only teaching physicians in residency training sites located outside of a metropolitan statistical area (MSA) may use audio/video real-time communication technology to meet the “present for key portion” requirement. • Teaching physicians can report levels 4-5 of an evaluation and management (E/M) service when the physician is physically present for the key portion of the service. • Does not apply to surgical, high-risk, interventional, other complex procedures, services performed through an endoscope, and anesthesia services. • Resident moonlighting – allows services not related to a resident’s approved graduate medical education (GME) program to be separately billable. • Outpatient (OP) department. • Emergency department (ED). • Inpatient services.
  • 40.
    © Health Catalyst.Confidential and Proprietary. • May no longer count resident time at alternate locations. • This includes their own home or a patient’s home. • A teaching hospital that sends residents to other hospitals cannot claim those residents in its Indirect Medical Education (IME) and Direct Graduate Medical Education (DGME) Full Time Equivalent (FTE) resident counts. • The presence of residents in non-teaching hospitals will trigger the establishment of IME and DGME FTE resident caps at the non-teaching hospital. • Temporary increase in beds. • Any added beds will be considered in determining the IME payments. • Regarding Inpatient psychiatric facilities (IPFs) and Inpatient Rehabilitation Facilities (IRFs), any change to the average daily census will be considered in determining teaching status adjustment payments. Workforce Flexibilities – Teaching Physicians
  • 41.
    © Health Catalyst.Confidential and Proprietary. Workforce – Hospital, Teaching Hospitals • Waivers are ending at the conclusion of the PHE. • Sterile compounding allowance of face mask to be removed and retained in the compounding area, to be reused during the same work shift in the compounding area. • Physicians whose privileges would have expired were allowed to continue practicing. • New physicians allowed to practice in a hospital before full medical staff/governing body review and approval. • Certified Registered Nurse Anesthetist (CRNA) physician supervision waiver. • Hospital written designation of the personnel qualified to perform specific respiratory care procedures and amount of supervision. • Critical Access Hospital (CAH) deferring all licensure, certification, registration, and minimum qualifications.
  • 42.
    © Health Catalyst.Confidential and Proprietary. CMS Hospitals Without Walls
  • 43.
    © Health Catalyst.Confidential and Proprietary. Acute Hospital Care at Home • The main Hospitals Without Walls flexibilities are ending. • Acute Hospital Care at Home expands on the Hospital Without Walls initiative. • Consolidated Appropriations Act, 2023 (CAA) expands program through 2024. • Must apply to participate.
  • 44.
    © Health Catalyst.Confidential and Proprietary. Hospitals Without Walls - Ending • The flexibilities are ending because CMS doesn’t have the authority to change the regulations. • Teaching Hospital Fact Sheet mirrors the Hospital fact sheet for this section. • Temporary expansion sites. • Providers temporarily enrolled as a hospital: • Ambulatory surgical centers (ASCs): • Must submit notification of intent to convert back to ASC status. • Must meet hospital certification standards to become a hospital. • Independent, free standing, emergency departments (IFEDs). • Off-Site Patient Screening.
  • 45.
    © Health Catalyst.Confidential and Proprietary. Hospitals Without Walls - Ending • Paperwork requirements: • Timeframe for providing a copy of a medical record. • Written policies & procedures on visitation of patients who are in COVID-19 isolation and quarantine processes. • Seclusion and restraint of patients. • Physical Environment requirements: • Facility and non-facility space not normally used for patient care. • Specific Life Safety Code: • Alcohol-Based Hand-Rub dispenser waiver of prescriptive and storage requirements. • Temporary construction of walls and barriers between patients. • Use of Provider-Based Departments (PBDs) as temporary expansion sites.
  • 46.
    © Health Catalyst.Confidential and Proprietary. Hospitals Without Walls - Ending • Supporting hospitals to more effectively respond to COVID-19 PHE. • Temporary extraordinary circumstances relocation exception policy for on-campus PBDs and excepted off-campus PBDs. • Streamlining process for relocating PBDs to seek the exception so providers can see patients and bill for services. • Allowing PBDs to relocate to more than one PBD location, or partially relocate, while remaining in the original location and receiving the full Outpatient Prospective Payment System (OPPS) amount. • Patient’s home. • Temporarily relocated PBDs that are permanently relocated will be considered new off- campus PBD. • Use modifier PN Non-excepted service provided at an off-campus, outpatient, provider-based department of a hospital. • Temporarily relocated excepted off-campus locations that permanently located need to follow standard extraordinary circumstances relocation process.
  • 47.
    © Health Catalyst.Confidential and Proprietary. Hospitals Without Walls - Ending • Hospital-Only Remote Outpatient Therapy and Education Services provided in the patient’s home as if they were furnished in-person. • Partial Hospitalization Program (PHP) services provided to a patient in their home. • Expanded ability for hospitals to offer long-term care services (swing beds) for patients who do not require acute care but do meet the Skilled Nursing Facility (SNF) level of care criteria. • Critical Access Hospital (CAH) status and location requirements relaxation. • Located in a rural area, or area being treated as rural. • Surge site locations. • Establish off-campus and co-location requirements.
  • 48.
    © Health Catalyst.Confidential and Proprietary. Hospitals Without Walls - Ending • Sole Community Hospitals (SCHs) eligibility requirements. • Market share and bed requirements. • Medicare-Dependent, Small Rural Hospitals (MDHs) requirements. • 100 or fewer beds. • 60% of inpatient days or discharges attributable to Medicare Part A. • Housing acute care patients in distinct part units. • Care for excluded inpatient psychiatric unit patients in the acute care unit of a hospital. • Care for excluded inpatient rehabilitation unit patients in the acute care unit of a hospital. • Inpatient rehabilitation facilities and the 60% rule. • All inpatients will be included in the inpatient population for purposes of calculating the thresholds.
  • 49.
    © Health Catalyst.Confidential and Proprietary. Hospitals Without Walls - Ending • Hospital-Only clinical staff in-person services where the patient’s home was considered to be a PBD for the purpose of receiving outpatient services. • Services required to be furnished by a health professional, such as infusion or wound care. • Reported as if performed at the hospital. • Require an order by the physician or NPP. • Require supervision, which may be through audio/visual communication.
  • 50.
    © Health Catalyst.Confidential and Proprietary. SNF-Specific Issues • Qualifying prior hospitalization stay: • Effective May 12, SNF patient admissions revert to pre-PHE requirements. • Patients admitted during PHE do not require the qualifying hospital stay until they’re discharged. • Patient may have a three-day break without issue. • The 30-day transfer policy doesn’t apply to patients who do not have a qualifying hospital stay. • Patient COVID-19 testing requirement technically ends with the PHE – BUT: • May continue as part of the national safety standard. • May follow infection control practices. • Same guidance applies to masking and handwashing.
  • 51.
    © Health Catalyst.Confidential and Proprietary. Telehealth and Remote Services
  • 52.
    © Health Catalyst.Confidential and Proprietary. Telehealth • Services furnished via telecommunication technology provided remotely to a patient who is a patient in the hospital, which may include the patient’s home if the home is declared a PBD. • The Consolidated Appropriations Act, 2023 (CAA) applies to professional services. • Hospital-Only remote outpatient therapy and education services. • Partial Hospitalization Program (PHP) services. • Telemedicine services provided to the hospital’s patients through an agreement with an off-site hospital. Facilities - Ending
  • 53.
    © Health Catalyst.Confidential and Proprietary. Telehealth • For PBDs, what can be reported when the physician or NPP provides telehealth to a patient at home? • The facility isn’t able to report anything for this service. • What about Q3014 or G0463? • The facility is not able to report either Q3014 or G0463 when the provider is in the facility and the patient is home. • HCPCS Q3014 Telehealth originating site facility fee may be reported when facility meets requirements as an originating site. • What about hospital-employed physical therapists (PTs), occupational therapists (OTs) or speech language pathologists (SLPs)? • They can’t provide telehealth services. • They can only provide services to patients physically within the hospital. Facility – Questions & Answers
  • 54.
    © Health Catalyst.Confidential and Proprietary. Telehealth • Medicare beneficiaries receiving telehealth services wherever they are located. • Extended through December 31, 2024. • Audio-only services in limited circumstances. • Extended through December 31, 2024. • Expanded list of approved telehealth services through 2023. • Watch for updates in the 2024 Medicare Physician Fee Schedule (MPFS) final rule. • Providers expanded to those who are eligible to bill Medicare for their professional services. • Extended through December 31, 2024. • No geographic restrictions, except for teaching physicians. Professional
  • 55.
    © Health Catalyst.Confidential and Proprietary. Telehealth • Continue with current reporting through December 31, 2023. • Place of service for 2024: • 02 Telehealth Provided Other than in Patient’s Home. • 10 Telehealth Provided in Patient’s Home. • Audio-only allowed in limited circumstances for diagnosis, evaluation, or treatment of a mental health or substance use disorder – ruling made permanent. • CPT® codes 99441-99443 will be allowed through 2024. • CMS advises providers to monitor the rule-making process. Professional
  • 56.
    © Health Catalyst.Confidential and Proprietary. Telehealth • If the provider is doing telehealth at home, do they need to update their enrollment information? • Generally, yes. The address is only viewable through Care Compare. • QPP@cms.hhs.gov Professional – Questions and Answers
  • 57.
    © Health Catalyst.Confidential and Proprietary. Remote Evaluations, Virtual Check-Ins & E-Visits • Providers who bill Medicare for their professional services may provide e-visits: • Non-face-to-face communications, such as using an on-line portal. • Physicians/NPPs may use 99421-99423. • Licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, speech language pathologists may use 98970-98972. • Policy made permanent in the 2021 MPFS Final Rule. • Clinicians must have an established relationship prior to providing remote physiologic monitoring (RPM) services. • PHE allowed 99453-99454 to be reported when 2 days of data collected in certain scenarios. • After PHE, returns to a minimum of 16 days of data collection to report. Professional
  • 58.
    © Health Catalyst.Confidential and Proprietary. Telehealth/Telemedicine • Removal of frequency limitations on certain telehealth services ends with PHE. • Subsequent inpatient visits could be telehealth once every 3 days. • Subsequent SNF telehealth visit once every 14 days. • Critical care consultation codes beyond the once per day limitation. • Patients with End Stage Renal Disease (ESRD) must have a face-to-face visit monthly and telehealth visits will no longer replace the face-to-face visit. • Restoration of language within National Coverage Determination (NCD) or Local Coverage Determination (LCD) in-person, face-to-face visits for evaluation or assessment no longer to be provided via telehealth. • Any NCD/LCD requiring a specific practitioner type or specialty reinstated. • Virtual check-ins only for established patients, and no longer available for new patients. Professional
  • 59.
    © Health Catalyst.Confidential and Proprietary. Telehealth • In-person delivery of MDPP services suspended through December 31, 2023. • Translation: telehealth delivery of services through 2023 allowed. • Original guidance stated: “through the end of the PHE.” • Allows for alternative to in-person weight measurement. • Eliminates the maximum number of virtual services. • Published in Federal Register on May 2, 2023. Medicare Diabetes Prevention Program (MDPP) Expanded Model Suppliers
  • 60.
    © Health Catalyst.Confidential and Proprietary. Reducing Administrative Burden (Stark Law)
  • 61.
    © Health Catalyst.Confidential and Proprietary. Reducing Administrative Burden – Waivers Ending • Stark Law waivers are ending. • Physician self-referrals, etc. • Must immediately comply with all provisions of the Stark Law. • Waivers also ending. • Pay above or below fair market value for physician’s services, rent equipment, or purchase items or services. • Financial support such as personal loans without charging interest. • Benefits such as multiple daily meals, personal laundry service, and free childcare. • Offering items or services that would exceed the non-monetary compensation cap. • Physician-owned hospitals temporarily increasing the number of licensed beds, operating rooms, and procedure rooms. • Furnishing magnetic resonance imaging (MRI) or computed tomography (CT) scans or laboratory services from locations like mobile vans in parking lots.
  • 62.
    © Health Catalyst.Confidential and Proprietary. Reducing Administrative Burden – Waivers Ending • Verbal orders where authentication may occur later than 48 hours. • Limited discharge planning for hospitals and CAHs to not use quality measures and data to select discharge entity. • Modified discharge planning where the patient may not receive a comprehensive list of nursing homes in the geographic area. • Completion of medical records within 30 days or “promptly” for CAHs. • Utilization review Conditions of Participation (CoP) requiring a utilization review plan and committee. • Quality assessment and performance improvement (QAPI) program scope of the program and setting priorities for the performance improvement activities. • Current therapeutic diet manual approved by dietitian and medical staff available did not need to be maintained during the PHE. • Delivery of advance directive policies to large number of patients.
  • 63.
    © Health Catalyst.Confidential and Proprietary. Reducing Administrative Burden • Inpatient Prospective Payment System (IPPS) Occupational Mix Survey collection is expected. • Medicare Geographic Classification applications must be submitted by September 1 of the year prior to the fiscal year (FY) 2023 or 2024. • Nursing services returning. • Develop and keep a nursing care plan for each patient. • Policies & procedures in place establishing which outpatient departments are not required to have a registered nurse present. • Surge facilities did not need to have written policies and procedures. • Surge facilities did not need to have emergency preparedness policies and procedures. • Signature requirements as proof of delivery for durable medical equipment (DME) items.
  • 64.
    © Health Catalyst.Confidential and Proprietary. Reducing Administrative Burden • Hospital Value-Based Purchasing (VBP) program’s Extraordinary Circumstances Exceptions (ECE): • CMS will review each on a case-by-case basis. • Will no longer consider ECE for COVID-19 after the PHE. • If you need an extension for filing your cost report, submit a request to your MAC. • Hotlines for provider enrollment will be shut down. • Continue to report data for COVID-19 and other respiratory illnesses through April 30, 2024.
  • 65.
    © Health Catalyst.Confidential and Proprietary. Questions? Q&A Document can be found on Healthcatalyst.com under Resources/Webinars
  • 66.
    © Health Catalyst.Confidential and Proprietary. Resources Coronavirus Waivers & Flexibilities: https://www.cms.gov/coronavirus-waivers COVID-19 Vaccines and Monoclonal Antibodies Reimbursement: https://www.cms.gov/medicare/medicare-part-b-drug-average-sales-price/covid-19-vaccines-and- monoclonal-antibodies National Stakeholder Call – 04/25/2023: https://www.cms.gov/outreach-education/partner-resources/cms-national-stakeholder-calls Acute Hospital Care At Home: https://qualitynet.cms.gov/acute-hospital-care-at-home
  • 67.
    © Health Catalyst.Confidential and Proprietary. Resources, cont. CPT® COVID-19 Vaccine and Immunization Codes (contains Appendix Q): https://www.ama-assn.org/practice-management/cpt/covid-19-cpt-vaccine-and- immunization-codes The White House Release: https://www.whitehouse.gov/briefing-room/statements-releases/2023/05/01/the-biden- administration-will-end-covid-19-vaccination-requirements-for-federal-employees- contractors-international-travelers-head-start-educators-and-cms-certified- facilities/#:~:text=Today%2C%20we%20are%20announcing%20that,19%20public%20health %20emergency%20ends.

Editor's Notes

  • #4 thing to remember as we walk through the updates is that the waivers and flexibilities were created to facilitate the acute phase of the pandemic and were not meant to be a permanent replacement. The waivers were only appropriate as emergency measures.
  • #6 This timeline was taken from the National Stakeholder Call held by CMS on 4/25/2023.
  • #7 This timeline was taken from the National Stakeholder Call held by CMS on 4/25/2023.
  • #8 These first few slides apply to pretty much all facilities and physicians or pharmacies.
  • #10 A hot topic at the National Stakeholder call was a variation of this question.
  • #25 f
  • #31 The list of CPT codes for COVID-19 tests also includes those for antibody testing. CMS has said that coverage of antibody testing is at the MAC’s discretion. Currently, code 86409 is priced locally by the MAC, the others are priced nationally. As a reminder, Medicare already has no cost sharing for laboratory tests
  • #40 Bullet 2 – residents no longer able to report Level 4-5 E/M services
  • #44 Link to the website where you can apply is in the references
  • #45 The fact sheet for hospitals includes Hospitals and CAHs (including Swing Beds, distinct patient units DPUs), ASCs and CMHCs The Teaching Hospital fact sheet mirrors the “normal” hospital fact sheet for the Hospitals without Walls section
  • #55 This first flexibility about receiving telehealth wherever the patient is located allows for performance within the US and appropriate territories. (Puerto Rico) Provision of service outside of the US is not a Medicare benefit, so if a patient is in Portugal, the service doesn’t qualify as a Medicare benefit (unchanged).