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CMS Makes Covid-19 Data Collection a Requirement in Conditions of Participation

The Centers for Medicare & Medicaid Services (CMS) is requiring Covid-19 data collection and reporting as a condition of participation (CoP) for hospitals participating in the Medicare and Medicaid programs, including psychiatric facilities.

CMS added the requirement with other provisions in an interim final rule and said it will accept comments for 60 days. The rule noted the requirement will become effective when it is published in the Federal Register, although it did not list a specific date.

Under the new requirement, hospitals will need to report daily data, including—but not limited to—the number of confirmed or suspected Covid-19 positive patients, intensive care unit beds occupied, and the availability of supplies and equipment, such as ventilators and personal protective equipment.

CMS warned in the rule that if a hospital fails to comply with this new CoP, it could face possible termination from the federal healthcare programs.

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NABH and Other Healthcare Groups Support Eliminating the Provider Relief Fund Tax Penalties Act

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HHS Extends Phase 2 General Distribution Deadline to Sept. 13

The Department of Health and Human Services (HHS) has extended the deadline to apply for Phase 2 General Distribution Funding for Medicaid, Medicaid managed care, Children’s Health Insurance Program, dental providers, and certain Medicare providers until Sunday, Sept. 13.

This funding is through the Provider Relief Fund, which the federal government established in this year’s Coronavirus Aid, Relief, and Economic Security Act (CARES) and Paycheck Protection Program and Health Care Enhancement Act. These payments do not need to be repaid to the government if providers comply with terms and conditions.

HHS has extended this Phase 2 General Distribution Funding deadline before, with the latest deadline scheduled for this Friday, Aug. 28. Providers now have a few extra weeks to apply.

Click here to read HHS’ six steps to applying for the Phase 2 General Distribution.

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2020 NABH Annual Survey Starts Aug. 28!

Data Collection for the 2020 NABH Annual Survey Starts this Week!
 
I am pleased to announce that data collection for the 2020 NABH Annual Survey will begin on Friday, Aug. 28. Your participation in this survey will help us continue to provide an accurate, up-to-the-minute picture of the U.S. behavioral healthcare industry. Please note that we have added a few new questions related to substance use. This will help us better measure our membership’s activities.

Look for a Message from Consulting Firm Dobson DaVanzo & Associates, LLC

Our contractor, Dobson DaVanzo & Associates, will conduct the NABH Annual Survey again this year. Dobson DaVanzo & Associates brings extensive data-analysis experience and data-security expertise to this project. The firm has analyzed data for the last several NABH Annual Surveys.

Dobson DaVanzo will send personalized links to the survey instrument via e-mail directly to the CEOs of all NABH-member hospitals and residential treatment centers. If you receive a request to participate in the survey, please respond as soon as possible.

Submit Your Data Online

The 2020 online entry form will provide a personalized, secure e-mail link for each facility. You will be able to enter, save, and review data— and review that data internally with others in your organization who have completed the survey—until you click “Done” on the survey’s last page. You may not make changes after you have submitted your data. You will receive complete instructions with the survey instrument.

Your Participation in Essential!

The survey data are used in dozens of ways to help protect mental health and addiction treatment benefits; ensure fair and adequate payments; improve patient care; and communicate trends to the media, payers, benefit consultants, and the public.

Within your organization, you can also use the NABH aggregate data you will receive to measure how your facility compares with national trends. Because the survey collects the most current information about the field, it can provide a valuable perspective for administrative and clinical operations. The NABH Annual Survey Report is an invaluable strategic planning tool as well as a reference document every behavioral healthcare organization should have.

If you have any questions or suggestions about this survey, please feel free to contact me directly at Shawn@nabh.org or contact Kirsten Beronio at Kirsten@nabh.org.

Thank you for your time. We appreciate your help!

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HHS to Host Provider Relief Fund Webinar on Thursday, Aug. 13

The Health and Human Services Department (HHS) will host an informational webinar for healthcare providers about applying to the CARES Act Provider Relief Fund this Thursday, Aug. 13 at 3 p.m. ET. Please click here to register.

HHS announced on July 31 that certain Medicare-participating providers would have another opportunity to receive additional Provider Relief Fund payments. These are the providers who missed an early June deadline to apply for additional funding equal to 2% of their total patient care revenue from the $20 billion portion of the $50 billion phase 1 General Distribution, including many Medicaid, Children’s Health Insurance Program (CHIP), and dental providers with low Medicare revenues. These eligible providers may now submit their application for possible funding by Friday, Aug. 28.

HHS has also extended the deadline to Aug. 28 for providers who participate in Medicaid and CHIP to apply for up to 2% of their total patient care revenue from a separate funding distribution for Medicaid providers.  To be eligible for this funding, providers must not have received any funding from the Medicare focused distribution of funding from the Provider Relief Fund.

Providers can access the same portal to apply for both Medicare-based and Medicaid-based funding.

HHS has hosted a series of webinars to address questions from providers throughout the application process, and Thursday’s webinar is the next provider and provider organization webinar in this series.

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Coalition Letter In Support Of TREATS Act

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NABH Analysis: CMS Proposes Expanding Medicare Telehealth Benefits and Scope of Practice Changes Beyond Pandemic

CMS Proposes Expanding Medicare Telehealth Benefits and Scope of Practice Changes Beyond Pandemic

The Centers for Medicare & Medicaid Services (CMS) is proposing to maintain—either permanently or temporarily— many of the Medicare telehealth benefits and workforce flexibilities authorized during the Covid-19 pandemic, according to the fiscal year 2021 Medicare physician fee schedule proposed rule the agency released Monday.

In issuing these proposed changes, CMS referred to President Trump’s Aug. 3 Executive Order on “Improving Rural Health and Telehealth Access” that directs the Health and Human Services secretary to propose regulations to extend flexibilities provided during the Covid-19 public health emergency (PHE) as appropriate.

Proposed Extensions of Medicare Coverage of Telehealth

On a permanent basis, CMS proposes to continue Medicare coverage for these telehealth services authorized during the PHE:

Home visits for the evaluation and management of an established patient: less complex and last typically 25 minutes,
Certain types of visits for patients with cognitive impairments,
Group psychotherapy,
Neurobehavioral status exams,
Care planning for patients with cognitive impairment,
Less complex domiciliary, rest home, or custodial care services, and
Prolonged evaluation and management (E/M) services.

CMS has requested public feedback on other services to add to this list of permanent Medicare-covered, telehealth services.

CMS is also proposing to extend Medicare coverage on a temporary basis for telehealth delivery of the following services until the end of the calendar year when the PHE ends:

Psychological and neuropsychological testing,
Emergency department visits,
Home visits to address moderate to severe issues, typically lasting 60 minutes,
More complex domiciliary, rest home, or custodial care services, and
Nursing facilities discharge day management.

CMS has also requested comments on this list of telehealth services that the agency proposes to cover temporarily in Medicare. CMS said it intends these temporary extensions of coverage to allow time for the agency to consider whether these services should be extended permanently.

In the proposed rule, CMS clarified that licensed clinical social workers, clinical psychologists, (as well as physical therapists, occupational therapists, and speech-language pathologists) can furnish the brief online assessment and management services via telehealth as well as virtual check-ins and remote evaluation services.

In addition, CMS has clarified that telehealth rules do not apply when the beneficiary and the practitioner are in the same location even if audio/video technology assists in providing a service.

CMS has not proposed to continue separate payments for audio-only evaluation and management services beyond the end of the PHE. Instead, the agency has requested comment on whether to develop coding and payment for a service similar to virtual check-in but for a longer unit of time with a higher value. CMS is seeking feedback on duration of services and resources required to furnish this service and also whether Medicare coverage of this audio-only service should be extended temporarily or permanently.

Meanwhile, CMS is proposing to allow direct supervision to be provided using real-time, interactive audio and video technology (excluding telephone that does not also include video) through Dec. 31, 2021. The agency is requesting comments on this proposal, including guardrails that should be in place and risks to patient safety and concerns about waste, fraud, and abuse.

CMS also included a number of clarifications about Medicare coverage for remote physiologic monitoring codes and new payment rates for immunization administration.

Updates to Evaluation and Management Codes

In this proposed rule, CMS has proposed revaluing a number of code sets that rely on or are analogous to E/M visits including psychiatric diagnostic evaluations and psychotherapy services.
CMS has also proposed simplified coding and billing requirements for E/M visits to take effect in January 2021.

Proposed Changes to Scope of Practice Rules and Related Issues

CMS has also proposed changes to allow healthcare professionals to practice up to the top of their professional training and to continue some of the workforce flexibilities allowed during the PHE, including:

Allowing nurse practitioners, clinical nurse specialists, physician assistants, and certified nurse-midwives (instead of only physicians) to supervise others performing diagnostic tests consistent with state law and licensure, providing that they maintain the required relationships with supervising/collaborating physicians as required by state law,
Clarifying that physicians and nonphysician practitioners, including therapists, can review and verify documentation entered into the medical record by members of the medical team for their own services that are paid under the Medicare physician fee schedule,
  • Accordingly, in the inpatient psychiatric facility prospective payment system final rule issued July 31, CMS also confirmed as final, changes to the special conditions of participation rules for psychiatric facilities allowing non-physician practitioners, or advanced practice providers (including physicians assistants, nurse practitioners, psychologists, and clinical nurse specialists) to document progress notes in accordance with state laws and scope-of-practice requirements.
Clarifying that therapy students, and students of other disciplines, working under a physician or practitioner who furnishes and bills directly for their professional services to the Medicare program, may document in the record so long as it is reviewed and verified (signed and dated) by the billing physician, practitioner, or therapist, and
Requesting comment on whether to continue temporarily or permanently Medicare coverage for services of residents that are provided outside of the scope of their approved GME programs and furnished to inpatients of a hospital in which they have their training program as separately billable physicians’ services.

Proposed Changes to Opioid Treatment Program Benefit

CMS has proposed making several changes to claiming rules and payment codes for the new Medicare Part B benefit for opioid use disorder services, including medications and services furnished by opioid treatment programs. Of note, add-on codes for nasal naloxone and auto-injector naloxone are proposed along with clarification on periodic assessment add-on code requirements.

SUD Screening in Medicare Initial and Wellness Visits

CMS is implementing a new requirement that the Medicare Initial Preventive Physical Examination and Annual Wellness Visit include screening of beneficiaries for potential substance use disorders, including a review of any current opioid prescriptions, as well as referral for specialty treatment, as appropriate. This new requirement was enacted in the SUPPORT Act.

Electronic Prescribing of Controlled Substances

CMS said it is implementing another SUPPORT Act provision that requires prescriptions of Schedule II, III, IV, or V controlled substances for Medicare Part D beneficiaries to be electronic. CMS issued a request for information on July 30 requesting feedback on whether to include exceptions to this requirement and whether CMS should impose penalties.

Public comments on this proposed rule are due by Monday, Oct. 5.

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HHS Extends Deadline for Provider Relief Funding Until Aug. 28

The Department of Health and Human Services (HHS) extended the deadline to Friday, Aug. 28 from Monday, Aug. 3 for healthcare providers who participate in Medicaid and CHIP to apply to the Provider Relief Fund established in the Coronavirus Aid, Relief, and Economic Security (CARES) Act.

HHS had previously extended this deadline to Aug. 3 from July 20. HHS said that it plans to issue a simplified application form soon.

In addition, HHS is re-opening the portal for Medicare-participating providers to apply for funding set aside from the Provider Relief Fund for Medicare providers. The previous deadline to apply for this distribution was June 3.

Providers will now have until Aug. 28 to apply for the balance of funding up to 2% of their annual patient revenue. HHS is re-opening this application process after learning that many providers, including many Medicaid and CHIP providers, did not apply to the prior Medicare-based distribution because they had relatively low Medicare revenues. 

HHS also announced it is working on another distribution of funding from the Provider Relief Fund focused on providers who have not received any of this funding, including those who only bill commercially or do not directly bill for the services they provide to Medicare and Medicaid beneficiaries.

Information on how to apply for the various Provider Relief Fund distributions is on HHS’ website.

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Wit v. UnitedHealthcare Hearing Delayed to Wednesday, Sept. 2

The remedies hearing in the Wit v. UnitedHealthcare case scheduled for this week has been delayed to Wednesday, Sept. 2.

NABH has learned that U.S. Chief Magistrate Judge Joseph Spero has re-scheduled the hearing due to meetings related to Covid-19.

Members of the public and press are welcome to join the webinar, and NABH will send an updated Zoom link when it becomes available.

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