In addition to changes in the Centers for Medicare & Medicaid Services (CMS) Interim Final Rule discussed in our previous update, Providers and practices should be aware of the following additional information and waiver flexibilities in the rule:
- Home Health Agencies can now provide additional services to patients via telehealth if it’s part of the patient’s plan of care and does not replace the needed in-person care as ordered in the plan of care.
- Hospice Organizations can provide services to Medicare patients via telehealth if feasible and appropriate to do so.
- Clinicians now have maximum flexibility in determining patient needs for respiratory-related devices and equipment and the flexibility for more patients to manage their treatments at home. The current National Coverage Determinations (NCDs) and Local Coverage Determinations (LCDs) that restrict coverage of these devices and services to patients with specific clinical characteristics do not apply during the Public Health Emergency. For example, Medicare will cover non-invasive ventilators, respiratory assist devices, and continuous positive airway pressure devices based on the clinician’s assessment of the patient. So, in summary, on an interim basis, CMS will not enforce clinical indications across respiratory (including home oxygen), home anticoagulation management, and infusion pump NCDs and LCDs (including articles).
The above policies include but are not limited to the following:
- Home Oxygen
- Continuous Positive Airway Pressure for Obstructive Sleep Apnea
- Respiratory Assist Devices (ventilators for home use)
- Intrapulmonary Percussive Ventilator
- Oxygen and Oxygen Equipment (for home use)
- Home Prothrombin Time/International Normalized Ratio (PT/INR) Monitoring for Anticoagulation Management
- Infusion Pumps
- External Infusion Pumps
For additional information:
- CMS Fact Sheet− “Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19”
- Medicare Learning Network (MLN) video − Medicare Coverage and Payment of Virtual Services
- HCCI COVID-19 Information Hub
Previous HCCI Updates related to COVID-19:
- COVID-19 HCCI Update Week of March 30th (04/01/20)
- COVID-19 Telehealth Billing Requirements (03/24/20, please refer to March 30th article)
- Providing Telephonic and Virtual Care Requirements as part of COVID-19 Precautions (03/17/20)
- COVID-19 Preparedness and Screening Questions for HBPC Practices and Providers (03/13/20)
Disclaimer: This information is current as of 4/08/2020. COVID-19 guidelines are changing daily. Please note for the purposes of the Home-Based Primary Care (HBPC) population: The Home Centered Care Institute (HCCI) focuses our content on CMS guidelines relevant for traditional Medicare billing. It’s always recommended to check with local MACs for specific guidance for your geographic region.