Pathology/Lab Coding Alert

With a focus on COVID-19 diagnostic testing and related genomic SARS-CoV-2 surveillance, there’s plenty of support that labs can expect from the $1.9 trillion COVID-19 relief bill known as the American Rescue Plan Act (ARPA) signed into law by President Biden in March.

Continuation: “The ARPA extends and expands some of the critical provisions in the CARES Act and the Consolidated Appropriations Act (CAA),” say Lisa Riccardi and Dan Kraft with VonLehman & Co. in online analysis.

Expect Stepped-Up Lab Funding

Beginning in fiscal year 2021, Health and Human Services (HHS) has $47.8 billion “to carry out activities to detect, diagnose, trace, and monitor SARS–CoV–2 and COVID–19 infections and related strategies to mitigate the spread of COVID–19,” according to the law.

This appropriation may specifically impact payment for laboratory testing services related to the following:

• Development, manufacturing, procurement, distribution, and administration of tests and supplies to detect or diagnose SARS–CoV–2 and COVID–19
• Acquisition, construction, alteration, or renovation of non-federally owned facilities for the production of diagnostics and ancillary medical products and supplies
• Establishment and expansion of testing by investing in laboratory capacity, such as academic, research or other laboratories for processing COVID-19 testing.
• The law also allocates 1.75 billion to “strengthen and expand activities and workforce related to genomic sequencing, analytics, and disease surveillance,” including the following:
• Conduct, expand, and improve activities to sequence genomes, identify mutations, and survey the circulation and transmission of viruses and other organisms, including strains of SARS–CoV–2
• Support public health departments and laboratories to increase genome sequencing capacity and identify mutations in circulating viruses and other organisms, including SARS–CoV–2.
• Support public health departments and laboratories to use genomic sequencing to identify outbreaks and clusters of diseases or infections, including COVID– 19, and to develop effective disease response strategies based on genomic sequencing and surveillance data
• Enhance and expand the informatics capabilities of the public health workforce
• Support construction, alteration, or renovation of facilities to improve genomic sequencing and surveillance capabilities at the state and local level.

Know These ARPA COVID-Relief Keys

In addition to ARPA provisions that directly impact lab testing, the law covers a wide swath of other COVID-19 healthcare-related needs such as vaccination, mental health, substance abuse, underserved communities, and children’s health and nutrition.

Here’s a brief overview of five items in the law that impact providers:

1. Rural provider relief: One element that made it into the bill was $8.5 billion allocated “for purposes of making payments to eligible healthcare providers [enrolled in Medicare or Medicaid] for healthcare related expenses and lost revenues that are attributable to COVID–19” in rural areas, the legislation specifies.

2. Medicare wage-index update: The legislation reinstates the Medicare wage-index floor for hospitals in all-urban states, starting on Oct. 1, 2021. The law “directs the HHS Secretary to create a Medicare area wage index for hospitals in all-urban states to address a 2019 rule that imposed across-the-board cuts to increase pay for low-wage hospitals,” clarifies law firm Holland & Knight in online analysis.

3. OIG: In an effort to boost oversight in 2021, the legislation provides the HHS Office of Inspector General (OIG) $5 million to investigate funding given to the Department of Health and Human Services (HHS) to address COVID-19 issues.

4. Public health workforce: The law allocates more than $9 billion to boost the public health workforce across a spectrum of programs including recruitment and hiring, grants, graduate medical education, and a Health Services Corp, among other items.

5. Accelerated payments: Even though the legislation offers a plethora of assistance specifically and adjacently to Medicare providers, it isn’t all rosy. One area of concern for providers was the absence of Medicare accelerated payments guidance.

ARPA “fails to provide loan forgiveness for Medicare accelerated payments for hospitals,” states the American Hospital Association (AHA) in a release on the legislation.

Given the historic financial challenges related to the COVID-19 pandemic, “it’s really about making sure hospitals and health systems have the resources needed to provide essential services for their patients and communities,” said Rick Pollack, AHA president and CEO in a press release.

That may be all: Since this latest iteration of COVID-19 relief falls under Congress’ budget for the fiscal year (FY) 2021, experts suggest providers shouldn’t expect another trillion-dollar haul any time soon.

“With vaccination rates climbing, the ARPA may be the last of the major legislative relief packages addressing the effects of the pandemic,” Riccardi and Kraft surmise.

Resource: Review the law at https://www.congress.gov/117/bills/hr1319/BILLS-117hr1319enr.pdf.