COVID-19 Updates: Latest Regulatory Information for ACG Members
From ACG Legislative and Public Policy Council Chair, Whitfield L. Knapple, MD, FACG
The Centers for Medicare and Medicaid Services (CMS) continues to announce temporary waivers and policy changes impacting ACG members in order to improve access to care and mitigate the damage caused by COVID-19. This week:
CMS Updates Recommendations on Elective Procedures: CMS recently updated recommendations to postpone non-essential surgeries and procedures to conserve resources and limit exposure of patients and staff to COVID-19.
PLEASE NOTE: While these updated recommendations do not specifically mention GI endoscopy, like the previous version, CMS confirmed with ACG this week that there has been no change to the agency’s recommendations to delay and postpone non-critical and elective GI procedures.
HHS begins disbursing CARES Act grants: On Friday, the U.S. Department of Health and Human Services (HHS) announced disbursement of the first $30 billion out of the $100 billion that Congress authorized in the Public Health and Social Services Emergency Fund in the Coronavirus Aid, Relief and Economic Security (CARES) Act. This initial $30 billion is being directed to hospitals and physician practices in direct proportion to their share of Medicare fee-for-service spending. The total amount of Medicare FFS spending in 2019 was $484 billion. As noted previously, the CARES Act language provides $100 billion for providers, including “public entities, Medicare or Medicaid enrolled suppliers and providers, and such for-profit entities and not-for-profit entities…that provide diagnoses, testing, or care for individuals with possible or actual cases of COVID–19.”
All facilities and health professionals that billed Medicare FFS in 2019 are eligible for the funds. These are grants, not loans, and do not have to be repaid. Of note:
- Employed Physicians: Employed physicians should not expect to receive an individual payment directly. The employer organization will receive the relief payment as the billing organization.
- Physicians in a Group Practice: Individual physicians and providers in a group practice are unlikely to receive individual payments directly. The practice would receive the relief fund payment as the billing organization.
- Solo Practitioners: Solo practitioners who bill Medicare will receive a payment under the TIN used to bill Medicare.
These are automatic payments that will come to the organizations via Optum Bank with "HHSPAYMENT" as the payment description. Some practices may have already received this payment from HHS.
Click here for additional details. This website also includes a link to Terms and Conditions for receipt of the funds that each organization receiving the grants will need to attest to within 30 days of receiving the grant. The funds may be used either for health care related expenses or for lost revenues that are attributable to coronavirus.
CMS “Dear Clinician” Letter: CMS posted a letter to clinicians this week that outlines a summary of actions CMS has taken to date. The summary includes information about telehealth and virtual visits, accelerated and advanced payments, and recent waiver information.
More CMS Waivers Announced: CMS also suspended certain rules so that healthcare facilities can hire doctors, nurses, and other clinicians. The waivers focus on reducing supervision and certification requirements so that practitioners can be hired quickly.
ACG Updated Guidance: Economic Relief for GI Practices
From ACG Board of Trustees Member Carroll D. Koscheski, MD, FACG
In last week’s update on economic relief for GI practices, I briefly discussed the Medicare Accelerated and Advanced Payments Program. Unlike the small business loan programs administered through the Small Business Administration (SBA), this program is strictly administered through the Centers for Medicare and Medicaid Services (CMS). The basic premise is that you present a 3-month estimate of your typical earnings based on historic information. Medicare will pay you this sum in advance. Your practice then pays off the sum owed to CMS over a period of time
This week, CMS announced that the agency approved approximately $34 billion for providers in one week. CMS updated this amount to over $51 billion. According to CMS, processing times are roughly 4-6 days. In a little over a week, CMS has already approved over 21,000 of the 32,000 requests it received from providers and suppliers. Prior to COVID-19, CMS had approved just over 100 total requests in the past 5 years, with most being tied to natural disasters such as hurricanes.
The premise is to calculate your typical Medicare reimbursement over a 3-month timespan and provide this as an immediate lump sum payment to your practice. This applies to Medicare Parts A and B and will include ASC facility fees, infusion fees, and pathology. You will continue to bill Medicare as always, and be reimbursed for services provided. After 120 days, Medicare will start recouping its costs. There is a 90-day timespan on recoupments that will be interest-free. Money owed beyond that 90 days will have interest added to the amount. You may repay the remaining amount in a lump sum at any time.
COVID-19 Crisis Action Plan for Gastroenterology Practices: 10 Actions Your Practice Should be Taking
From ACG Practice Management Committee Chair Louis Wilson, MD, FACG
During my recent special edition ACG podcast entitled “ACG Leadership in a Time of Disruption” with ACG President Dr. Mark Pochapin and President-Elect Dr. David Greenwald, Dr. Pochapin pointed out that the Chinese characters for “crisis” are a combination of the characters for “danger” and “opportunity.” Although it’s uncomfortable to call a terrible infectious pandemic an opportunity, I realize that it’s critical for practicing physicians to view it that way.
While hospitalists, intensivists, and critical care nurses are certainly on the frontlines taking care of COVID-19 infected patients, gastroenterologists must avoid being pushed to the sidelines and must take meaningful action. This is the time for gastroenterologists to respond with leadership and foresight, contribute to emergency efforts and improve the way we do things. Today I’m sharing some of the actions I consider important for practicing gastroenterologists at this time.
1. Emergency PSA with your Hospital
Now is the time to approach your hospitals for emergency expansion of your current professional service agreements, or for new ones. Click here to read the full blog post.