COVID-19 Updates

Direct Deposits, Supervision Relaxation, Staffing Requirements Changed, and Modifier CS!


It is a busy Friday! 

Direct Deposits 

The CARES Act included $100 billion for providers to cover their “lost revenue.” This morning HHS paid out the first $30 billion to providers based on Medicare revenues from last year, no application necessary.

The payments are based on your 2019 Medicare revenue and where made to each Taxpayer Identification Number used to bill Medicare.

We understand that even though the link says “fee-for-service” reimbursements, in this context, RHC reimbursements are counted.

For those of you who are pediatric-focused or have a lower share of Medicare patients, HHS is working on ways to push out the remaining $70 billion so there may be a cash infusion coming your way soon.

For those of you that are hospital owned, or in a system, please verify within your organization that your system/hospital got the money and the payment was calculated on system-wide Medicare revenues.

The money does come with some strings attached. You will need to certify that your RHC is meeting these terms and conditions.

Supervision of Nurse Practitioners in RHCs Relaxation

CMS is relaxing supervision requirements for NPs. This is for the emergency period effective March 1, 2020 through the end of the emergency declaration. From CMS:

Physician supervision of NPs in RHCs and FQHCs. 42 C.F.R. 491.8(b)(1).

We are modifying the requirement that physicians must provide medical direction for the clinic’s or center’s health care activities and consultation for, and medical supervision of, the health care staff, only with respect to medical supervision of nurse practitioners, and only to the extent permitted by state law. The physician, either in person or through telehealth and other remote communications, continues to be responsible for providing medical direction for the clinic or center’s health care activities and consultation for the health care staff, and medical supervision of the remaining health care staff. This allows RHCs and FQHCs to use nurse practitioners to the fullest extent possible and allows physicians to direct their time to more critical tasks.

Staffing Requirements Waived (50% NP/PA/CNM Requirement)

CMS is also waiving the requirement (for the emergency period retroactive back to March 1, 2020) that RHCs have a PA, NP, or CNM available to furnish care at least 50% of the time the RHC operates. Again from CMS:

Certain staffing requirements. 42 C.F.R. 491.8(a)(6).

CMS is waiving the requirement in the second sentence of § 491.8(a)(6) that a nurse practitioner, physician assistant, or certified nurse-midwife be available to furnish patient care services at least 50 percent of the time the RHC and FQHC operates. CMS is not waiving the first sentence of § 491.8(a)(6) that requires a physician, nurse practitioner, physician assistant, certified nurse-midwife, clinical social worker, or clinical psychologist to be available to furnish patient care services at all times the clinic or center operates. This will assist in addressing potential staffing shortages by increasing flexibility regarding staffing mixes during the PHE.

Modifier CS – Waives Cost Sharing for Patients and Pays Provider 100%

Use modifier CS for all COVID-19 testing-related services for Medicare patients. This modifier will waive any cost sharing obligation for the patient and pay the provider 100% of their payment. In our case, this means that claims with modifier CS will be paid at 100% of your all-inclusive rate.

This modifier can be used for office and outpatient services such as an Evaluation and Management service to determine if the patient needs a COVID-19 test. It can also be used for digital evaluation and management services that are for the purposes of determining if a patient needs a COVID-19 test or not.