The PHE Ended, Now What?

CMS has an FAQ available for leaders needing to catch up on revenue cycle changes now that the public health emergency (PHE) has ended.

The COVID-19 PHE has officially concluded, and to assist providers during this transition, CMS released an FAQ to clarify the end to various waivers and flexibilities affecting the revenue cycle and beyond.

CMS will continue to pay providers approximately $40 per dose for administering vaccines through the end of the calendar year (CY) in which the vaccine’s emergency use authorization (EUA) declaration ends. The EUA declaration is distinct from, and not dependent on, the PHE, and it is still in effect. Starting January 1 of the year after the one in which the EUA declaration ends, CMS will align the administration payment rate for COVID-19 vaccines with the administration payment rate for other Part B preventive vaccines, which is currently $30 per dose.

These rates do not apply for Federally Qualified Health Centers, rural health clinics, or other settings that are paid at a reasonable cost for preventive vaccines and their administration. Medicare will also continue to pay approximately $36 plus regular administration fees for COVID-19 vaccines administered at home through the end of CY 2023.

The enforcement discretion that allows mass immunizers to bill Part B directly for vaccines furnished to skilled nursing facility (SNF) patients will end on June 20, 2023. “Beginning on July 1, 2023, SNFs will be responsible for billing vaccines furnished to SNF patients in a Part A stay,” stated the FAQ.

Medicare coverage of COVID-19 treatments are remaining the same. For diagnostic testing, beneficiaries can continue to receive COVID-19 PCR and antigen tests with no cost-sharing if the test is performed by a laboratory and ordered by a physician.

The three-day stay requirement for SNFs is no longer in effect. Any covered SNF stay that began on or prior to May 11, 2023, without a qualifying health stay (QHS) can continue for as many benefit days as the patient has available, given all criteria are met. However, covered SNF stays that begin after May 11 will require a QHS.

Many Medicare telehealth flexibilities have been extended through December 31, 2024. However, CMS noted that individuals will now no longer be able to receive routine home care via telehealth under the hospice benefit.

The FAQ detailed billing practices for the following codes now that the PHE concluded:

• Q3014 (originating site facility fee) should not be billed unless the beneficiary is located within a hospital and receives a telehealth service from an eligible distant site practitioner.
• G0463 (clinic visit) can be billed if a beneficiary is within a hospital and received an outpatient clinic visit, including mental/behavioral health, from a practitioner in the same physical location.
• C7900–C7902 (remote mental health services) can be billed if the patient is in their home and received a mental/behavioral health service from hospital staff through the use of telecommunications technology and no separate professional service can be billed.

Additionally, hospitals are no longer able to bill Q3014 “to account for resources associated with administrative support for a professional Medicare telehealth service,” according to the FAQ.