Medicare Compliance & Reimbursement

Find out the scoop on PRF payments and reporting, codes, and policies.

If your practice is trying to keep COVID-19 news in check — and remain in compliance with the most up-to-date Medicare-related changes — you’re not alone. Read on for the details.

The Centers for Medicare & Medicaid Services (CMS) Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule with Comment Period (IFC) continues to dominate the pandemic news and is likely first on your organization’s to-do list as you work to implement policies and vaccinate staff according to the mandate (see story, p. 3).

There are, however, other critical COVID-19-inspired updates that providers should know. Take a look at four important policies that impact your Medicare business.

1. PHE Is Renewed for an 8th Time

On Jan. 14, Health and Human Services (HHS) Secretary Xavier Becerra renewed the COVID-19 Public Health Emergency (PHE) effective Jan. 16. Originally, the PHE was slated to expire on that date, but with this latest declaration is now extended for another 90 days.

This eighth update follows previous 2021 renewals on Oct. 18, July 19, April 15, and Jan. 7. Before that, former HHS Secretary Alex Azar renewed the PHE declaration in 2020 on Oct. 2, July 23, and April 21. The original PHE declaration was effective Jan. 27, 2020.

Reminder: As part of the PHE, the federal government allows for regulatory leniency and relaxed federal guidelines to accommodate providers struggling under COVID-19’s impact. This includes 1135 waivers and other flexibilities related to various Medicare policies and regulations.

The last update to CMS’ “COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers” document was Nov. 29, 2021. Find the 1135 waivers at www.cms.gov/files/document/covid-19-emergency-declaration-waivers.pdf and the HHS Secretary’s declaration at https://aspr.hhs.gov/legal/PHE/Pages/COVID19-14Jan2022.aspx.

2. HHS Distributes Billions in PRF Phase 4 Payments

HHS via the Health Resources and Services Administration (HRSA) has continued its significant Provider Relief Fund (PRF) assistance with its Phase 4 general distribution that started in December 2021, helping healthcare providers and suppliers combat COVID-19.

Details: HRSA dispensed $9 billion in PRF payments as part of the Phase 4 distribution in December 2021, and another $2 billion went out this January, according to a Jan. 25 HHS update.

Important: This Phase 4 tranche was “based on changes in operating revenues and expenses from July 1, 2020 to March 31, 2021,” HRSA guidance indicates. “Phase 4 payments also include new elements specifically focused on equity, including reimbursing smaller providers for their changes in operating revenues and expenses at a higher rate compared to larger providers, and bonus payments based on the amount of services providers furnish to Medicaid/Children’s Health Insurance Program (CHIP) and Medicare beneficiaries.”

Though more than 76,000 providers and suppliers have already received Phase 4 payments, there may be more distributions ahead as the agency has only processed 82 percent of the applications.

“The Provider Relief Fund remains an important tool in helping to sustain the critical health care services communities need and support the health care workforce that is delivering on the frontlines every day,” acknowledges HRSA Administrator Carole Johnson in a release on the most recent Phase 4 distributions.

Find the list of PRF payment recipients at https://data.cdc.gov/Administrative/HHS-Provider-Relief-Fund/kh8y-3es6.

3. PRF Reporting Period 2 Is Now Open for Business

The next round of PRF reporting has arrived. “Healthcare providers who received Provider Relief Funds from July 1, 2020, to Dec. 31, 2020, will need to report how they used those funds,” says accounting firm Casey Peterson in online guidance. “The PRF reporting portal that opened for reporting period 2 on Jan. 1, 2022, will stay open until March 31, 2022.”

Logistics: “Providers who received one or more General and/or Targeted PRF payments exceeding $10,000, in the aggregate, from July 1, 2020 to December 31, 2020 must report on their use of funds in Reporting Period 2,” HRSA reminds on its website.

A handy new feature is that “the Portal will auto-populate previously entered data in certain fields,” HRSA notes in a “What’s New” fact sheet for period 2. “Providers can edit and update any auto-populated fields.”

Tip: “Returning Reporting Entities may change the methodology for calculating lost revenues, but must then use the new methodology to calculate lost revenues for the entire RP2 Period of Availability,” HRSA advises in the fact sheet.

Extra: HRSA offers online guidance for providers who may have missed Period 1 reporting and are now out of compliance with the requirements. If you missed the deadline and are now considered non-compliant, review this fact sheet on next steps and possible penalties at www.hrsa.gov/sites/default/files/hrsa/provider-relief/reporting-non-compliance-fact-sheet.pdf.

Head up: Reporting Period 3 opens on July 1, and Reporting Period 4 opens on Jan.1, 2023, HRSA notes on its PRF reporting and auditing website.

Get the scoop and log in to the portal at https://prfreporting.hrsa.gov/s/.

4. CDC Releases New Diagnosis Code Options for Vaccination Status

If a patient presents to your practice and is unvaccinated for COVID-19 — or even partially vaccinated — you’ll soon have a way to code that condition.

The Centers for Disease Control and Prevention (CDC) released a new ICD-10-CM code set effective April 1 for coding COVID-19 vaccination status, indicates CMS in an MLN Matters release (Change Request 12578) on Jan. 14.

The offerings include the subcategory code Z28.31 (Underimmunized for COVID-19 status) and three additional diagnosis options:

• Z28.310 (Unvaccinated for COVID-19)
• Z28.311 (Partially vaccinated for COVID-19)
• Z29.39 (Other underimmunized status)

Note: The CDC adds a note to the codes in Chapter 21 of the ICD-10-CM tabular list and addendum: “These codes should not be used for individuals who are not eligible for the COVID-19 vaccines, as determined by the healthcare provider.” Find more details at https://ftp.cdc.gov/pub/Health_Statistics/NCHS/Publications/ICD10CM/2022/icd10cm-tabular-addenda-2022-April-1.pdf.

Additionally, the ICD-10 guidelines also offer more clarity. “Underimmunization for COVID-19 Status Code Z28.310, Unvaccinated for COVID-19, may be assigned when the patient has not received at least one dose of any COVID-19 vaccine. Code Z28.311, Partially vaccinated for COVID-19, may be assigned when the patient has received at least one dose of a multi-dose COVID-19 vaccine regimen, but has not received the full set of doses necessary to meet the Centers for Disease Control and Prevention (CDC) definition of ‘fully vaccinated’ in place at the time of the encounter.

For information, visit the CDC’s website https://www.cdc.gov/coronavirus/2019-ncov/vaccines/,” explain the guidelines.

Find the ICD-10-CM official guidelines at https://ftp.cdc.gov/pub/Health_Statistics/NCHS/Publications/ICD10CM/2022/10cmguidelines-FY2022-April-1-update.pdf.