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Download our summary of coding and reimbursement during the COVID-19 pandemic:

COVID-19 Coding/Reimbursement Summary

For a comprehensive summary of the changes to telemedicine, including billing changes, applicable during the COVID-19 public health emergency, please download the following bulletin:

COVID-19 TELEMEDICINE BULLETIN


Billing 

AMA Information on new CPT codes for COVID-19.
 
Q:  Can I get paid by Medicare for counseling patients to self-isolate when testing is ordered?

A:  Yes, if certain criteria are met. Follow this link for additional information.

 
Q:  When testing and treating uninsured individuals for COVID-19, what option is available for reimbursement?

A:  To provide support to health care providers for COVID-19 testing and treatment for uninsured individuals with a COVID-19 diagnosis, the U.S. Department of Health and Human Services will provide reimbursement,  generally at Medicare rates. For more information about how the program works go to https://www.hrsa.gov/CovidUninsuredClaim.

 
Q:  Can 99211 be billed for COVID-19 specimen collection?

A:  According to the April 30, 2020 Interim Final Rule with comment, if the services described by code 99211 are provided to assess for COVID-19 and specimen collection, 99211 can be billed. The code can be billed for both new and established patients. Direct supervision for the specimen collection can be met by virtual presence of the supervising physician or practitioner with interactive audio or video technology.

 
Q:  Has the “typical time” definition for E/M level selection furnished via telehealth during the public health emergency changed?

A:  Previously “typical time” was defined as all of the time associated with the E/M on the day of the encounter. The “typical times” were available in a public file and were not the times listed in the office/outpatient E/M code descriptors. These discrepancies were causing confusion. Now “typical times” for the selection of an E/M level will be the times listed in the code descriptors.

 
Q:  Do we need to resubmit claims for Audio Only Telephone E/M Visits (99441, 99442 and 99443)?

A:  CMS has instructed the Medicare Administrative Contractors (MAC) to make claim adjustments, and there is no need to resubmit. Claims, for dates of service March 1, 2020 and after, that were submitted and not covered, will be reprocessed by your MAC. If the claim was paid at the lower rate, they will reprocess with the increased allowance. These claim adjustments will take place in stages.

 
Q:  What are the telehealth requirements for modifier usage during the Public Health Emergency?

A:  Please see the CMS document regarding modifier usage.

 


Financial Assistance - Government Programs

Under the leadership of President Trump, the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), is announcing $20 billion in new funding for providers on the frontlines of the coronavirus pandemic. Under this Phase 3 General Distribution allocation, providers that have already received Provider Relief Fund payments will be invited to apply for additional funding that considers financial losses and changes in operating expenses caused by the coronavirus. Previously ineligible providers, such as those who began practicing in 2020 will also be invited to apply, and an expanded group of behavioral health providers confronting the emergence of increased mental health and substance use issues exacerbated by the pandemic will also be eligible for relief payments.

Providers can begin applying for funds on Monday, October 5, 2020.

The Department of Health & Human Services (HHS) has released new guidance on the reporting requirements for physicians and practices that received Provider Relief Fund payments. Here are the websites that detail that information.

Cares Act Provider Relief Funds

HHS Provider Relief Auditing

HHS Provider Relief Reporting

HHS Provider Relief Reporting Elements

Q:  Where can I find MGMA-specific COVID-19 information?

A:  MGMA COVID-19 Action Center

 
Q:  Where is the CDC Information for Healthcare Professionals?

A:  CDC Coronavirus 2019 Healthcare Professionals Index

 
Q:  Where can I find the Medicare Quality Program details?

A:  QPP Program Details

 
Q:  What is OIG doing about Coronavirus?

A:  With the rapid emergence of waivers and relaxing of laws related to the Coronavirus epidemic, there are scammers already trying to take advantage of the situations.  This site keeps Compliance Officers up-to-date on the OIG's guidance's and FAQs.

 
Q:  What information is available concerning my state's Medicaid services?

A:  Section 1135 Medicaid Waivers, at least 23 states have approved waivers.  The list at this site gives State specific information.

 
Q:  Can I see a Medicaid patient if my practice is not licensed to see Medicaid patients?

A:  Each state has different rules surrounding this.  Find the information for your state here.

 
Q:  I need more information about the CARES Act passed by Congress on March 27, 2020.
  • This document from MGMA provides the key provisions affecting medical groups in the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act.
  • This document from the AMA provides high level guidance for practice owners and administrators as their practice are confronting new and unique operational and business challenges as they manage patients during the COVID-19 pandemic.
  • The U.S. Small Business Administration has provided this site with comprehensive information for small business owners.  There is a line to the Coronavirus (COVID-19) application for an Economic Injury Disaster Loan.  This link will assist physicians in determining their entities eligibility for such a loan.
  • The SBA provides low-interest disaster loans to help businesses and homeowners recover from declared disasters. This site provides information on the process and a link to the application. 
 
Q:  Is there a comprehensive list of CMS flexibilities to fight COVID-19?

A:  This document provides a comprehensive list of and links to the flexibilities that CMS has implemented to fight COVID-19.  This includes Telehealth services, Workforce issues and Stark Law waivers.

 
Q: Our practice is participating in the Quality Payment Program (QPP) Merit-based Incentive Payment System (MIPS) in 2020 – given the health crisis, is there any relief available for us?

A: Yes, if you have been significantly impacted by COVID-19, you can submit an Extreme & Uncontrollable Circumstances Application to reweight any or all of the MIPS performance categories. Keep in mind that if you fill out this application requesting relief, you must also be prepared to provide justification of how your practice has been significantly impacted. 

 
Q: Our practice serves mostly Medicaid eligible patients and we’ve not received any Federal funds, is there anything available for our practice?

A: Yes, as of June 8, 2020, HHS announced enhanced provider portal, relief fund payments for Safety Net Hospitals, Medicaid and CHIP providers.  Clinicians that participate in state Medicaid and CHIP programs and/or Medicaid and CHIP managed care organizations who have not yet received General Distribution funding may submit their annual patient revenue information to the enhanced Provider Relief Fund Portal to receive a distribution equal to at least 2 percent of reported gross revenues from patient care. This funding will supply relief to Medicaid and CHIP providers experiencing lost revenues or increased expenses due to COVID-19. Examples of providers, serving Medicaid/CHIP beneficiaries, possibly eligible for this funding include pediatricians, obstetrician-gynecologists, dentists, opioid treatment and behavioral health providers, assisted living facilities and other home and community-based services providers.
Application information can be located here.   

 
Q:  Will there be a second round of payments from the Provider Relief Fund?

A:  Providers who received payments through the Provider Relief Fund may be eligible for a second round of funding from the Provider Relief Fund.  They must apply for these funds on the following link:  https://covid19.linkhealth.com/docusign/#/step/1.  

 

Q:  Will a borrower’s PPP loan forgiveness amount (pursuant to section 1106 of the CARES Act and SBA’s implementing rules and guidance) be reduced if the borrower laid off an employee, offered to rehire the same employee, but the employee declined the offer?

A:  No. As an exercise of the Administrator’s and the Secretary’s authority under Section 1106(d)(6) of the CARES Act to prescribe regulations granting de minimis exemptions from the Act’s limits on loan forgiveness, SBA and Treasury intend to issue an interim final rule excluding laid-off employees whom the borrower offered to rehire (for the same salary/wages and same number of hours) from the CARES Act’s loan forgiveness reduction calculation. The interim final rule will specify that, to qualify for this exception, the borrower must have made a good faith, written offer of rehire, and the employee’s rejection of that offer must be documented by the borrower. Employees and employers should be aware that employees who reject offers of re-employment may forfeit eligibility for continued unemployment compensation.   For more information on the Paycheck Protection Program, see the Treasury Department's FAQs.

Q: Should we take any action on the “HHSPAYMENT” or “HHS Stimulus”money the practice received in its bank account?

A:  Yes. On April 10, HHS began issuing provider relief funding via direct deposit and checks to hospitals and other healthcare providers to support expenses or lost revenue as authorized by the CARES Act. These are payments, not loans subject to repayment. They are available to all providers and facilities that received Medicare fee for service reimbursement in 2019. HHS partnered with UnitedHealth Group and Optum Bank to distribute the funds according to information on file with United, Optum, or Medicare. Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. You may also choose to reject the funds. If you received these funds, you should review the eligibility and requirements available at https://www.hhs.gov/provider-relief/index.html. The portal for attestation/rejection is open via the same link.

Q:   Is there a number I can call if I have not received my provider relief HHS Stimulus Payment?

A:  HHS partnered with UnitedHealth Group (UHG) to deliver the initial distribution to providers. Physicians who believe they should have received funds but did not can contact UHG’s Provider Relations at (866) 569-3522.
UHG representatives can answer questions about eligibility, whether payment has been issued and where it was sent. UHG is continuing to issue disbursements and expects to complete the direct deposit payments by the first week of May.

Q:  I understand there are loans available for small businesses, including medical practices.  What are the options and how do I apply?

A:    This helpful fact sheet does a great job of explaining the different programs that are available.  There are four options available through the Small Business Administration (SBA):

  • Paycheck Protection Program
  • Economic Injury Disaster Loan (EIDC) Emergency Advance
  • SBA Bridge Loans
  • SBA Debt Relief

 

Q:  What is the repayment term for medicare loans made to providers during COVID-19?

A:  CMS announced new repayment terms! New recoupment terms allow providers and suppliers one additional year to start loan payments. Review this fact sheet to get more information. 


Insurance Carrier Links

        

BCBS       Cigna

CMS       Humana

Medicaid       UHC

 

 

 

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