Many practices and healthcare providers have faced extraordinary financial pressures during the outbreak of COVID-19. At this time, Congressional lawmakers have built (and the Senate has passed) several stimulus and relief bills. The latest of these is a $2 trillion stimulus bill, and many practices are now asking how this legislation may help them. I would like to share my interpretation of the measures presented in the latest and preceding bills, and how I believe this bill will provide relief to independent practices.
The American Hospital Association (AHA), American Medical Association (AMA), and American Nurses Association (ANA) together made a call to action to Congress to allocate $100B of direct funding to health care personnel and providers in response to this pandemic. This call to action laid out 3 priorities for Congress:
- Stabilization fund for emergency COVID-19 related expenses. The AHA calls for funds to support training and also emergency equipment, and operations including housing and quarantine facilities for patients not requiring hospitalization.
- Childcare funding for frontline healthcare personnel to reduce risk of staffing availability shortages
- Surge bed capacity to repurpose large structures and outpatient facilities, or to create new temporary structures to increase total inpatient capacity.
The largest COVID-19 related stimulus package allocates $100B in response to the call for action by the AHA, AMA, and ANA to reimburse providers and hospitals for lost revenues and expenses endured in the pandemic. This funding will be made available on a rolling basis through “the most efficient payment systems practicable to provide emergency payment.” $27B will also be made available to fund the development of vaccines, create surge capacity, and facilitate other preparedness activities including modernization and telehealth access.
The bill focuses on hospitals, providing a 20% payment increase to hospitals for COVID-19 related services, and providing accelerated or advance payments for qualifying hospitals. The bill also creates requirements for the payment for COVID-19 tests by employers and health insurers, and lifts previously imposed Medicare payment cuts. CMS will also enable hospitals to transfer patients to outside facilities, including hotels and dormitories, while still receiving hospital payments under Medicare, and is taking several other measures to support hospitals in providing benefits to medical staff and reducing administrative burdens.
Of great importance and relevance for independent practices, the bill does make policy changes to expand the ability of PAs, nurse practitioners, and certified nurse specialists to enable ordering of home-based health services, as well as increasing flexibilities for Medicare reimbursement of telehealth services. This expands upon the previously passed stimulus packages by removing the requirement that patients had been treated in the past three years. Further, CMS has made 80 new telehealth codes available for payment, has expanded reimbursement to include patients who only have audio phones, and has expanded availability of remote patient monitoring. These packages, which passed earlier in March, greatly relaxed or removed many eligibility requirements for telehealth services for office visits, mental health counseling, and preventative screenings. The previous package also increased reimbursement rates for telehealth visits to match those of in-person visits and waived originating site requirements. Further, flexibility was provided to waive coinsurance and deductible application, waiving cost-sharing requirements. In short, telehealth and home-based services are receiving continued enablement and support. Further measures are expected to be made to continue to expand on enabling remote care.
The legislation also provides for accelerated payments and advance payments through Medicare for providers who have billed Medicare claims within the last 180 days prior to the request, and who are not in bankruptcy, under medical review or integrity investigation, and without outstanding delinquent Medicare overpayments.
Finally, the legislation does include other general provisions relevant for independent practices, such as making loans available for organizations with fewer than 500 employees, which may be forgivable in qualifying circumstances. Employers may also be eligible to delay the 6.2% employer payroll tax due between April 2020 and December 31, 2020, deferring payment over two years, to 50% by December 2021 and the remaining 50% by December 2022.
It is my personal interpretation and opinion that the thus-far introduced measures may be very helpful in the response to COVID-19, as reimbursement requirements by private insurers for COVID-19 testing is a fantastic measure wherever tests are available. However, this does not provide permanent financial relief for lost revenues derived from decreased patient visits for independent practices. Many of the measures above provide for improvements in cash availability and cash flow timing (loans and advances or accelerated payments). Many practices may be playing financial “catch up” for months or years to come unless they take decisive action now to take advantage of the specific measures above, which facilitate reimbursement for remotely delivered services, most notably the expansion of telehealth reimbursement and availability of home-based health services.
Amazing Charts has made telehealth software available to our providers as quickly as possible, and we are exerting great effort to make meaningful software integration updates for this functionality in the days and weeks to come. Beyond this, we are partnering to make Practice Support available to help practices capture revenue from expanded reimbursement of home-based services, by rapidly connecting with remote clinical staff and billing for remotely delivered care plans for eligible patients. This can create real billable revenues and provide the proactive care that patients need in order to reduce hospitalizations, keep our practices running, and defray or prevent permanent financial losses from revenue downturns.
Many of the above listed measures provide for improvements in cash availability and cash flow timing (loans and advances or accelerated payments). However, many practices may still be playing financial “catch up” for months or years to come, unless they are so fortunate as to receive loan forgiveness which is certainly not guaranteed. Tools such as telehealth and practice support can help your practice immediately and allow you provide quality care for you patients. We are with you and will continue to communicate changes as they are announced.
Thanks for working to keep us safe,
Ben Scharfe is a CPA, CA who has been with Harris Healthcare for over five years and is currently a member of the Amazing Charts leadership team.
For more information and resources for handling the COVID-19 crisis, visit our dedicated COVID-19 page here.