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Proposed RHC Telehealth Legislation

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Due to COVID, we have seen how out-of-date telehealth regulations had been.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

Improving Telehealth for Underserved CommunitiesTeleHealth Act of 2020!

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RHC and FQHC Telehealth Legislative Update:

Contact US Congresspeople and Senators to support “The Health Act”!

On Thursday, June 18th, the Improving Telehealth for Underserved Communities Act was introduced in the Senate by Sen. Cindy Hyde-Smith (R-MS) and Sen. Angus King (I-ME).

“Thanks to the leadership of Sen. Hyde-Smith and Sen. King, the RHC community is one step closer to fixing our telehealth reimbursement issues” said Bill Finerfrock, Executive Director of the National Association of Rural Health Clinics.

Please support the Health Act. 

  • RHCs and FQHCs bill telehealth visits through their normal reimbursement mechanisms throughout the COVID-19 public health emergency.
  • Costs associated with telehealth are incorporated into annual cost reporting.
  • Telehealth visits count toward RHC productivity standards.
  • Claims data is accurate because accurate coding would be used, rather than the single G2025 code.
  • No recoupment period in July.
  • See One Page summary here:  Health Act One Page Summary.
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HHS Medicaid-CHIP Provider Distribution!

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HHS is distributing $15 billion to eligible Medicaid/CHIP providers. Each provider will receive at least 2 percent of reported gross revenue from patient care. The final amount will be determined from data submitted to HHS.

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.

Please follow us on Facebook and Twitter!

RHC Emergency Preparedness Rule

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RHC providers have new requirements!  CMS issued new Emergency Preparedness Rules which apply to all 17 provider types. As a result, Rural Health Clinic (RHC) providers need some upgrade! Please see my accompanying presentation which summarizes the CMS Rule.  The rule text was my sole source of information and text.

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.

Line-Item Billing for RHCs

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CMS has issued another update to the Rural Health Clinic Line-Item billing requirements being implemented on April 1, 2016.  Many Rural Health Clinics, independent and provider-based, will have to make significant software changes to deal with this.  The change is described in the MedLearn Matters MM9269, which was updated again today.

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

 

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