This blog post is based on an Industry Insight Webinar: COVID-19 Enrollment and Financial Implications, Facts and Resources
Hospitals have been operating in a national emergency for a few weeks now, which has dramatically altered credentialing and privileging processes. Providing care to patients and responding to this pandemic is the focus of your staff and the entire healthcare system right now. But to keep your business healthy and serving patients, you will have to get reimbursed for services rendered.
Here’s what you should know about Medicare/Medicaid’s response to the disaster and how it impacts credentialing and enrollment.
In certain circumstances, the Secretary of the Department of Health and Human Services (HHS) using section 1135 of the Social Security Act (SSA) can temporarily modify or waive certain Medicare, Medicaid, CHIP, or HIPAA requirements, called 1135 waivers. There are different kinds of 1135 waivers, including Medicare blanket waivers. When there's an emergency, sections 1135 or 1812(f) of the SSA allow the issue of blanket waivers to help beneficiaries access care. When a blanket waiver is issued, providers don't have to apply for an individual 1135 waiver.
Emergency requirements were met on: 3/12/20
The declaration allows for:
The declaration does not allow for:
CMS implements specific waivers or modifications on a “blanket” basis when a determination has been made that all similarly situated providers in the emergency area need such a waiver or modification. Once approved, these waivers apply automatically to all applicable providers and suppliers. Providers and suppliers do not need to apply for an individual waiver if a blanket waiver is issued by CMS.
There is a 26-page document listing all Medicare Blanket Waivers available here. But the following are a few key waivers that pertain to credentialing and enrollment:
This waives requirement for an out of state practitioner to be licensed in the state they are providing services in when licensed in another state. To be eligible, practitioners:
This pertains to several enrollment requirements.
Individual waivers can also be issued for states and provider/suppliers. These only need to be applied for if something is needed beyond what is provided under an existing Medicare blanket waiver.
Two new areas in this emergency are:
Flexibilities at the state-level for Medicaid program requirements could include:
As of April 14, 2020, CMS has approved 50 emergency waivers, 28 state amendments, 9 COVID-19 related Medicaid disaster amendments & one CHIP COVID-related disaster amendment.
CMS has been focusing since 2019 on expanding the use of tele-health services and allowing for payments for those, but the focus has greatly increased during the COVID-19 National Emergency. Eligible services have been expanded to include 80+ services including mental health counseling, preventive health screenings, emergency department visits and more. The requirement to have face-to-face contact with a patient, has also been lifted. Making use of proper codes when billing will be critical for reimbursement of these services. More information can be found here.
CMS is also authorized to provide Accelerated Advance Payments during this public health emergency to any provider and/or supplier who submits a request and meets requirements. They have delivered over $50 billion through expansion of Accelerated Advance Payments. These advance payments are loans providers must pay back. This funding is separate from the $100 billion provided in the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The CARES Act appropriation is a payment that does not need to be repaid. More information on submitting requests for APPs can be found here.
Much is being done to address both the needs of patients and the needs of economy during the COVID-19 pandemic. CMS is making it easier to get more providers on the frontline and expanding the scope of services covered to meet emerging health needs. On March 27, 2020 the President signed a $2.2 Trillion stimulus plan, which allocated $130 billion in relief funds for the medical and hospital industries. Commercial payers are doing their part with expedited credentialing and accelerated payments. And, organizations like the CAQH are also focused on bridging the gap between payers and providers to be sure patients continue to receive critical care during these turbulent times.
If you have credentialing, enrollment or reimbursement questions – you are not alone. VerityStream and our partners are here to help.