COVID-19 RESOURCES FOR RHCS

MARHC is working to ensure that providers are up-to-date on the latest news relevant to the COVID-19 pandemic. Please find a variety of resources below. We will update this page as resources become available. 

  • County Stimulus Funds: 

    • Per Missouri's SFY 2020 supplemental budget, $520,925,478 of the federal COVID-19 stimulus funds will be distributed to counties.  This does not include Jackson County and St. Louis County.  Due to their population size, they received funds directly from the federal government.  

    • The Treasurer's Office has developed a document with the anticipated amount each county will receive from the stimulus funds.  The distribution is based on county population.  

    • In order to receive the money, each county's executive must sign a certification that money will be spent in line with the federal guidance. A draft certification is here.  Below are a few key points from the document: 

      • Funds must be spent on necessary expenditures incurred due to the public health emergency with respect to COVID-19.  

      • Funds are to cover costs that were not accounted for in the budget most recently approved as of March 27, 2020

      • Funds must be used to cover costs incurred between March 1, 2020 and December 30, 2020. 

      • Funds cannot be used as a revenue replacement for lower than expected tax or other revenue collections.

    • CARES Act Funding - Opportunities for Economic Relief

    • CARES Act Webinar with Missouri State Treasurer

   

  • HHS Announces $10 Billion for Rural Health Clinics and Rural Hospitals  - On April 22, 2020, HHS updated their provider relief website with additional information about how they plan to spend the rest of the $100 billion allocated for healthcare providers by the CARES Act.In this update, HHS made it clear that rural health clinics and rural hospitals will receive $10 billion. Specifically, the announcement states:

    Allocation for rural providers

    • $10 billion will be allocated for rural health clinics and hospitals, most of which operate on especially thin margins and are far less likely to be profitable than their urban counterparts.
    • This money will be distributed as early as next week on the basis of operating expenses, using a methodology that distributes payments proportionately to each facility and clinic.

    • This method recognizes the precarious financial position of many rural hospitals, a significant number of which are unprofitable.

    • Rural hospitals are more financially exposed to significant declines in revenue or increases in expenses related to COVID-19 than their urban counterparts.

  • The Missouri Department of Economic Development has launched a Missouri PPE marketplace to will allow private and public sellers to connect with buyers. Register here - https://ppe-supply.uk.r.appspot.com/#/

  • FCC:  FCC COVID-19 Telehealth Program.  The FCC approved an Order to create a $200 million telehealth program to support healthcare providers responding to the ongoing coronavirus pandemic, using funds appropriated as part of the CARES Act.  The COVID-19 Telehealth Program will help healthcare providers purchase telecommunications, broadband connectivity, and devices necessary for providing telehealth services.  FCC's COVID-19 Telehealth Program Application Portal.

  • Telehealth Considerations, lessons learned to help as your clinic considers how to remain engaged with patients throughout the pandemic

 

 

 

 

 

 

 

 

The following organizations and departments are also updating their websites with new information and resources for COVID-19 daily.

 

 

 

 

 

Highlights: NARHC Webinar, April 20, How & What Will Medicare Pay for RHC Telehealth Visits

  • Distant site telehealth services can be furnished by any health care practitioner working for the RHC within their scope of practice.  Practitioners can furnish distant site telehealth services from any location, including their home, during the time they are working for the RHC and can furnish any telehealth service that is approved as a distant site telehealth service under the Physician Fee Schedule. 

  • Payment for RHCs for distant site telehealth services is set at $92 per visit.  

  • For telehealth distant site services furnished between January 27 and June 30, 2020: 

    • RHCs must use modifier 95. 

    • RHCs will be paid at their all-inclusive rate. 

    • These claims will be automatically reprocessed in July when the new Medicare claims processing system is updated with the new payment rate. These claims do not have to be resubmitted for the adjustment.   

    • Medicare claims for RHC telehealth visits occurring since January 27th will be paid by Medicare. If you have been holding these telehealth claims, you can submit them and they will be paid.

  • CMS has established a uniform RHC telehealth payment rate of $92.00 per visit. This rate will apply to telehealth visits performed by independent or provider-based RHCs

  • All RHCs will bill for telehealth visits the same as you would bill for an in-person visit and use the 95 modifier on the claim line to signify that the visit was via telehealth rather than in-person.

  • In order to expedite adoption of this policy, CMS will INITIALLY pay the RHC’s all-inclusive rate for this visit.

  • Beginning in July, CMS will automatically adjust ALL RHC telehealth claims to reflect the $92 telehealth per visit rate that were submitted between now and July 1, 2020. RHCs with a per-visit rate below $92.00 will receive an additional payment reflecting the difference between their AIR and $92.00. For RHCs with an AIR above $92.00, CMS will RECOUP the difference.

  • After July 1, 2020, through end of the COVID-19 Emergency,RHCs will use G Code G2025 to identify distant site telehealth visit services. This code will reimburse $92.00 and no recoupment will be necessary. 

  • Costs associated with the delivery of a telehealth visit will be reported on the RHC cost report however, they will be included in line 79 of the cost report, non-reimbursable RHC costs. This is so that RHC telehealth costs and telehealth visits will not be counted when determining the RHCs cost-per visit.  

  • The combination of reduced patient volume due to COVID-19 and the determination that RHC telehealth visits are not RHC visits could affect the ability of many RHCs to meet the minimum productivity requirements for cost reporting purposes.  NARHC is working with CMS on this.  

  • RHCs will need to develop a mechanism for tracking both telehealth visits and costs in order to properly account for these on the cost report.  

  • Retroactive to March 1, CMS will pay 100% of the RHC rate - including telehealth - for visits and services related to COVID-19 testing.  For these, RHCs must way collection of co-insurance.  

  • Even if the telehealth service is not related to COVID-19, providers have the option to waive coinsurance for telehealth visits and services.  

  • NARHC is working on getting clarification on when to use the CG code.  

  • Digital Visits and Virtual Checks must be patient initiated.  Telehealth Visits do not have to be patient initiated. 

  • NARHC's understanding is G0071 can only be billed once every seven days for a patient.  

Highlights: NARHC Webinar, April 3, Surviving Covid-19 as a Rural Health Clinic: New Federal Policies & Programs to Help Keep Your Clinic Open

On Friday, April 3, NARHC hosted a webinar on Surviving COVID-19 as a Rural Health Clinic.  The slides will soon be available on narhc.org under the Resources |TA Webinars page along with a recording of the webinar.  Below are a few takeaways from the presentation.  RHC’s are encouraged to download the slides and recording for full information.

 

Telehealth

  • Medicare differentiates between three types of technology-based visits: Medicare telehealth services, virtual check-ins, e-visits.  Cost-sharing can be waived for all of these.  Verbal consent is allowed, but it should be noted.  Policy is very fluid right now.  

  • Virtual Check In:  This contact cannot lead to a visit within 24 hours/ next available appointment.  It also cannot be follow-up to a visit within the previous 7 days.  These rules still apply during the public health emergency.  This can now be billed for new patients during the emergency.  

  • Digital E-Visits: RHCs could not bill for this originally.  However, this week CMS expanded G0071 to include digital e-visits for RHCs (for the emergency period). As of March 1, G0071 will pay $24.76 to RHCs.  During the emergency period, this can be used for new and established patients.  This cannot be a follow up for a service provided within the last seven days.  If it is related to a separate condition from the visit, it may be billed.  This cannot be billed if the patient comes in within 7 days.  Consent must be obtained, but for the public health emergency, it can be provided at the point of care or by staff.  This should be billed on the UB-04 with no modifier, using revenue code 0521.  

  • Telehealth: Medicare requires simultaneous audio and visual.  Medicare expanded the list of services that can be performed via telehealth in response to COVID.  Before COVID, RHCs could not be a distant site, and Medicare patients could not be at home for the originating site.  Now, they are waiving enforcement of HIPAA-compliant technology, RHCs can be a distant site, and patients can be at home. It still has to be audio and video.  As of March 30, CMS is now paying for audio-only evaluation services.  This is ONLY for fee-for-service.  If RHCs do audio-only, it has to be billed under G0071.  NARHC is going to go back to CMS about this discrepancy.  The telehealth changes only take effect for the emergency, but there is speculation some changes will remain.  Billing for RHCs as a distant site for telehealth is still unclear.  We don't know how to bill or how much the payment will be.  The Secretary will develop a payment method.  The costs for telehealth services cannot be used to determine the all-inclusive rate.  

 

Financial Relief 

  • Paycheck Protection Program: Most RHCs will be able to receive a forgivable loan equal to 2.5 times the clinic's qualified monthly payroll. To be forgiven, the clinic owner must attest they have the same number of employees at the end of the loan (eight weeks) that they did at the beginning. If you terminate employees or reduce salaries (under $100,000) by over 25% you may have to pay it back over two years at 1% interest.  You must apply through a local participating bank.  

  • SBA: If you have an existing SBA loan, you may qualify for the interest and principal of the loan to be paid for 6 months.  Also, under the Economic Injury Disaster Loan, you can borrow up to $2M, including a $10,000 grant up front.  It can be repaid over 30 years.  

  • Medicare Advance Payments: CMS is relaxing requirements to apply for an advance on future Medicare claims.  Application is through your Medicare Administrative Contractor.  Repayment begins automatically 120 days after the advance, and it must be repaid within 210 days of receiving the advance.  Medicare will take repayment from your claims. 

  • Provider Lost Revenue: This offers providers grants for lost revenue or increased costs due to COVID.  Since RHCs are paid on a cost-basis, lost revenue is the most likely way for clinics to apply.  This program is not yet operational.  This can cover Medicare, Medicaid, and commercial losses.  

Other

  • NARHC has asked CMS to provide additional flexibility on RHC staffing requirements.  

  • NARHC is working on allowing telehealth via audio-only.  Perhaps in the fourth COVID bill.  

  • CMS is extending the deadline for submitting cost reports.  

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