Due to COVID, we have seen how out-of-date telehealth regulations had been. It is essential the legislative changes be made to expand Telehealth statutes for Rural Health Clinics and FQHCs. As soon as the Public Health Emergency ends, Telehealth services and reimbursement will go back to the “old normal”.  We will no longer be able to provide services as the distant site. 

Please contact your US Senators and US Representatives.  Advocate for change!

H.R. 6792/S. 3998 – Improving Telehealth for Underserved Communities Act of 2020

• allows RHCs/FQHCs to bill for telehealth through their normal reimbursement mechanisms for the duration of the Public Health Emergency.
• raises the RHC cap to $92.03

Link To Senate Bill 3998

Link to HR 6792

H.R. 7187 – HEALTH Act of 2020

• Permanently establishes RHCs/FQHCs as distant site providers paid through normal mechanisms (telehealth services would also count as visits)
• Makes the payment methodology explicit.
• Eliminates originating site requirements for telehealth services furnished by RHCs/FQHCS

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Before applying through the enhanced provider relief portal, applicants should:

Read the Medicaid Provider Distribution Instructions – PDF*

Download the Medicaid Provider Distribution Application Form – PDF*

If the facility did not get money from the targeted RHC relief payment, we highly recommend this route. Multiple CCN numbers can be reported. Please see here for Provider Relief Fund information:

Provider Relief Fund Information

Please give us a call at 314.968.0076 extension 201 to request more information or email us at info@northamericanhms.com.

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CMS has allowed RHCs to determine which Emergency Meds are appropriate for the RHC.  These are stated in 42 CFR 491.9(c)(3).  This includes the following: “analgesics, anesthetics (local),antibiotics, anticonvulsants, antidotes and emetics, serums and toxoids.”  This is an extremely dated medication list – think 1977.  Most of us do not know what serums and toxoids are?

I have NEVER been to an RHC that had used, or were glad they had, an anticonvulsant.  It is stocked for the survey.  It never is used.  The medication expires.  It gets replaced, to never be used again.

There was a recent controversy over whether RHCs must stock snake venom antidote.  Even if there was not a specific risk in the RHC’s geographic area of snake bite.  Now we have the answer. We do NOT have to store snake venom antidote.

On September 3, 2019, the Centers for Medicare and Medicaid Services (CMS) released  “Revised Rural Health Clinic (RHC) Guidance Updating Emergency Medicine Availability—State Operations Manual (SOM) Appendix G- Advanced Copy.

Summary:  The Centers for Medicare & Medicaid Services (CMS) is updating the medical emergency guidance as it pertains to the availability of drugs and biologicals commonly used in life saving procedures.

Your Emergency Medication policy should be re-written to include consideration of each of the medication groups listed in 491.9(c)(3).  After considering each of these, state which medications will be stored.  It should also be documented who made the final decision.  This would preferably be the RHC Medical Director and/or NP/PA.

The updated text says:

“…when determining which drugs and biologicals to have available in order to provide medical emergency procedures as a first response to common life-threatening injuries and acute illness es, an RHC must consider each of the categories listed in regulation.

While each category of drugs and biologicals must be considered, all are not required to be stored. An RHC must have those drugs and biologicals that are necessary to provide its medical emergency procedures to common life-threatening injuries and acute illnesses.

In making this determination, the RHC should consider, among other things, accepted medical standards of practice, community history and the medical history of its patients.

The RHC should have written policies and procedures for determining what drug/biologicals are stored to provide such emergency services. The policy and procedures should also reflect the process for determining which drugs/biologicals to store, including who is responsible for making this determination.

They should be able to provide a complete list of which drugs/biologicals are stored and in what quantities. Since RHCs and federally qualified health centers (FQHCs) share the same regulatory requirements as it relates to emergency procedures under 42 CFR 491.9(c)(3), this revision will also apply to FQHCs.

The post RHC Emergency Medication Requirement 2019 first appeared on North American Healthcare Management Services.

This is an example of the Medicare RHC Negative payment when the whole charge and deductible amount exceeds the RHC encounter rate.  Medicare Negative Payments Example

The correct way to get these posted to your patient accounts?  However you can get it to balance!!

Have fun!

Charles

The post Medicare RHC Negative Payment first appeared on North American Healthcare Management Services.

RHC Emergency Preparedness Presentation

Rule Change Background

On September 8, 2016 the Federal Register posted the final rule Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers. The regulation goes into effect on November 16, 2016. Health care providers and suppliers affected by this rule must comply and implement all regulations one year after the effective date, on November 16, 2017.

Purpose: To establish national emergency preparedness requirements to ensure adequate planning for both natural and man-made disasters, and coordination with federal, state, tribal, regional and local emergency preparedness systems. The following information will apply upon publication of the final rule:

• Requirements will apply to all 17 provider and supplier types.
• Each provider and supplier will have its own set of Emergency Preparedness regulations incorporated into its set of conditions or requirements for certification.
• Must be in compliance with Emergency Preparedness regulations to participate in the Medicare or Medicaid program. The below downloadable sections will provide additional information, such as the background and overview of the final rule and related resources.

The post RHC Emergency Preparedness Rule first appeared on North American Healthcare Management Services.

CMS has been making consistent updates to this policy.  The latest issue is that there is no accurate means to code a procedure only visit.  Rural Health Clinics have many questions about this change to line-item billing.  The main issue is the CMS has issued a Rural Health Clinic Qualifying Visit List.  The list only has evaluation and management codes, but no CPT codes for minor surgical procedures.  This means that the only way to bill a minor surgical procedure is with an inaccurate code.  CMS has not yet updated the Qualifying Visit list with minor surgical procedure.

Rural Health Clinics will no longer bundle many of their services.  Rural Health Clinics will need to list the service detail along with the relevant revenue code.  This will include the ability to separately list venipuncture, preventive services, injections, and other incident-to services.  This is a “sea-change” for most Rural Health Clinics.

This WILL go into effect – do not wait for it to be delayed.

“Effective April 1, 2016, RHCs, including RHCs exempt from electronic reporting under Section 424.32(d)(3), are required to report the appropriate HCPCS code for each service line along with the revenue code, and other required billing codes. Payment for RHC services will continue to be made under the All-Inclusive Rate (AIR) system when all of the program requirements are met. There is no change to the AIR system and payment methodology, including the “carve out” methodology for coinsurance calculation, due to this reporting requirement. ”

The full CMS guidance for Rural Health Clinics can be found here:  https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9269.pdf

The post Line-Item Billing for RHCs first appeared on North American Healthcare Management Services.

The Office of Inspector General’s recently released work plan formalizes this scrutiny:

“We will determine the number of provider-based facilities that hospitals own and the extent to which CMS has methods to oversee provider-based billing. We will also determine the extent to which provider-based facilities meet requirements described in 42 CFR Sec. 413.65 and CMS Transmittal A-03-030, and whether there were any challenges associated with the provider-based attestation review process. Provider-Based status allows facilities owned and operated by hospitals to bill as hospital outpatient departments. Provider-based status can result in higher Medicare payments for services furnished at provider-based facilities and may increase beneficiaries’ coinsurance liabilities.

The Medicare Payment Advisory Commission (MedPAC) has expressed concerns about the financial incentives presented by provider-based status and stated that Medicare should seek to pay similar amounts for similar services. (OEI; 04-12-00380; expected issue date: FY 2016)

Comparison of Provider-Based and Freestanding Clinics
We will review and compare Medicare payments for physician office visits in provider-based clinics and freestanding clinics to determine the difference in payments made to the clinics for similar procedures and assess the potential impact on Medicare of hospitals’ claiming provider-based status for such facilities. Provider-based facilities often receive higher payments for some services than do freestanding clinics. The requirements to be met for a facility to be treated as provider based are at

42 CFR § 413.65(d). (OAS; W-00-14-35724; W-00-15-35724; expected issue date: FY 2016)”

OFFICE OF INSPECTOR GENERAL
U.S. Department of Health and Human Services
WORK PLAN Fiscal Year 2016 Page 6 and 7
http://www.oig.hhs.gov/reports-and publications/archives/workplan/2016/oig-work-plan-2016.pdf

North American Healthcare Management Services has specific expertise in successfully attesting to Provider-Based Rural Health Clinic status for clients.  We are encouraging all of our Provider- Based Rural Health Clinics let us assess their provider-based compliance so that when a re-attestation request comes (giving the clinic 10 days to respond), it is not a reason to panic.  Please call for a consultation.

Charles James

President and CEO

North American Healthcare Management Services

The post Provider-Based Rural Health Clinics 2016 first appeared on North American Healthcare Management Services.

I presented the following information to the National Association of Rural Health Clinics (NARHC) Spring Conference in 2015.  This presentation provides and overview of the Merit-Based Incentive Program announced by CMS.  This program was codified in the Medicare and S-CHIP Re-Authorization Act of 2015.

Volume to Value Spring 2015

To date: Rural Health Clinics are largely unable to participate in  Medicare Quality Incentives.  As person passionate about Rural Health Clinics, I believe this is to our detriment.  If Rural Health Clinics to not get in the quality game, we will be left behind.  We all know that the Rural Health Clinic program is essential to our ability to provider primary care in rural areas.

Please let me know how we can help your Rural Health Clinic navigate these issues.

Best Regards,

Charles James

President and CEO

North American Healthcare Management Services

Your Rural Health Clinic experts!

The post Medicare Incentives and Rural Health Clinics 2015 first appeared on North American Healthcare Management Services.

• Definitions, §491.2 The definition of a “physician” has been revised to include a doctor of dental surgery or dental medicine, a doctor of podiatry or surgical chiropody, or a chiropractor, within the limitations of services these types of physicians are permitted to offer under Section 1861(r) of the Social Security Act. However, it continues to be the case that only MDs or DOs may fulfill the requirements for supervision, collaboration and oversight of non-physician practitioners in an RHC or FQHC.

• Staffing and Staff Responsibilities, §491.8 §491.8(a)(3) was revised to permit an RHC to have a nurse practitioner or physician assistant provide services under contract to the RHC. This increased flexibility does not eliminate the longstanding statutory and regulatory requirement that the RHC must have at least one employee who is a nurse practitioner or physician assistant. This change was effective July 1, 2014. §491.8(a)(6) was revised to require for RHCs that a nurse practitioner, physician assistant, or certified nurse-midwife is available to furnish patient care services at least 50% of the time the RHC operates.

This aligns the regulatory language with the current statutory requirement. Note that since the statutory provision was self-implementing, CMS has enforced the 50% standard even prior to this regulation change. (See S&C 09-14) §491.8(b) has been revised to delete the requirement formerly at §491.8(b)(2) for a physician to be present in the RHC or FQHC at least once every two weeks. This recognizes that many of the physician’s required functions may be performed remotely via electronic means, but does not remove the requirement that a practitioner, whether a physician or non-physician practitioner, must be present at all times the RHC or FQHC operates. Provisions formerly at §491.8(b)(1)(i) – (iii) have been renumbered to be §491.8(b)(1) – (3), but are otherwise the same.

Rural Health Clinic Survey Letter 15-22

The post Rural Health Clinic Survey and Certification Letter 15-22 first appeared on North American Healthcare Management Services.

This IS indeed, the case.  Rural Health Clinics are exempt from PQRS penalties.  The problem is a technical one.  The PQRS penalty is based on fee-for-service, CMS-1500 claim submissions.  These claims are paid based on individual, Medicare Part B provider numbers associated with Medicare Part B, non-RHC, group numbers.

CMS does not have a way to associate these non-Rural Health Clinic provider numbers with Medicare Part A, RHC PTAN numbers.

Keep in mind:  the penalty is NOT assessed against Rural Health Clinic Part A payments.  The penalty is only levied on non-RHC services such as hospital, lab, and x-ray.  Your own exposure to these non-Rural Health Clinic penalties should be limited.

Unfortunately, ANY 1500 non-RHC billing will have the penalty applied if no 2013 quality data was submitted and no qualifying hardship was documented.  CMS recently issued a PQRS FAQ statement to this affect.  The penalties being currently applied are based on data submitted (or not) from 2013.  In order to avoid the penalty for 2016, please refer to the following link:

http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2014PQRS__Avoiding2016PQRS-PaymentAdjustment_F03-27-2014.pdf

For the time being, these penalties will continue to be assessed on your non-Rural Health Clinic provider numbers.

Please call with any questions.

Charles James

President and CEO

North American Healthcare Management

Your Rural Health Clinic Experts!

The post PQRS and RHC first appeared on North American Healthcare Management Services.