Through the CARES Act, the Centers for Medicare & Medicaid Services (CMS) enacted a permanent change to the Home Health rules.  The changes now allow NPs and PAs to certify and perform Home Health supervision or certification.  Previously, only physicians could bill for these services.  Effective for claims with dates of service on or after March 1, 2020, Nurse Practitioners (NPs), certified Clinical Nurse Specialists (CNSs), and Physician Assistants (PAs) may bill the following codes:

• G0179: Physician re-certification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians to affirm the initial implementation of the plan of care. Arizona Medicare rate is $40.39 (MD/DO); $34.33 (NPP) (This is for the provider recertifying every 60 days). A copy of the signed 485 form should be in the chart.
• G0180: Physician certification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians to affirm the initial implementation of the plan of care. This is for the provider’s initial certification. Arizona Medicare rate is $52.75 (MD/DO); $44.84 (NPP). A copy of the signed 485 form should be in the chart.
• G0181: Physician supervision of a patient receiving Medicare-covered services provided by a participating home health agency (patient not present) requiring complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans. This one requires 30 calendar minutes a month of the provider documenting on a daily basis what they were doing, regarding the patient’s HHA services. Arizona Medicare rate is $106.72 (MD/DO); $90.71 (NPP).

Implementing Home health may create questions, but we can help you find the answers.  If you want more information on this or other strategies designed to improve patient outcomes and quality of life, boost provider quality scores, or increase practice revenue then click here to fill out a brief survey to include any specific questions you may have (requires registration of a valid email address to communicate with).
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Reference:
Section 3708 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L. No. 116-136) amended sections 1814(a) and 1835(a) of the Social Security Act.

The scope and size of the projected COVID-19 financial impact is shocking. 
According to the National Association of ACOs (NAACOS), factoring of variances in disease severity, hospitalization rates, etc., the epidemic could cost Medicare more than $115 billion over the next year.  They assess this will hit clinics that participate in ACOs since providers are held accountable for their patients’ associated healthcare costs.  Likewise, Medicare Advantage plans face similar challenges.  NAACOS anticipates ACOs will experience a 6 – 18% spending increase due to COVID-19. 
NAACOS and other organizations with a substantial stake in the transition to alternative payment methods and value-based models continue to seek CMS and the federal government to provide some protection against the anticipated penalties that could result. 
Healthcare is historically recession-proof; illness occurs in bad times like in good times and insurance covers most associated costs.  However, the recession looming from COVID-19 may prove significantly different.  Unemployment is increasing nationwide and money is getting tighter in the face of uncertainty.  On top of that, in many cases insurance coverage is tied to employer-sponsored plans.  For those still employed and covered, more people have historically high deductibles and cost-shares making them less likely to seek care and fill prescriptions. 
Clinics are feeling the pinch, too, as people opt to stay at home rather than seek care – and clinics strive to minimize the risk of disease spread by limiting which patients come in and for what.  Some primary care clinics report up to 70% reductions in use of health care services, which means in about 45 days, a 70% reduction in revenue.  Granted, some of those services are merely deferred and will likely occur later, maybe in the summer.  Still, clinics need solutions now to generate revenue, so they can remain open for later.  Also, without the routine face to face with their patients, providers need the tools to keep in touch and to manage their patients, especially those at the greatest risk.
This is where clinics should consider services like Chronic Care Management (CCM) and Remote Physiologic Monitoring (RPM, aka Remote Patient Monitoring).  These are two strategies that are very straight forward and can be applied to 100% of clinics that see Medicare patients.  Additionally, if the practice can support it, reduced restrictions for telehealth services and other non-face-to-face services enable providers and staff to remain engaged with patients and generate revenue otherwise lost if unable to see patients in office. 
Since the beginning of the PHE, more and more primary care clinics are experiencing lower patient volume, reduced revenue, PPE shortages, etc. and many are unsure how long they can sustain operations; the financial strain is impacting their ability to keep the doors open, lights on, and staff employed.  Introducing CCM and RPM now can help your clinic and your patients not only in the short term, but sustainably into the future.
For more information on  CCM and RPM strategies, click here. 
References:
Cutler, David. (2020) How Will COVID-19 Affect the Health Care Economy? Retrieved from https://jamanetwork.com/channels/health-forum/fullarticle/2764547
Leventhal, R. (2020). Projected Financial Impact of COVID-19 Leaves Healthcare Leaders Searching for Help. Retrieved from https://www.hcinnovationgroup.com/finance-revenue-cycle/article/21131880/projected-financial-impact-of-covid19-leaves-healthcare-leaders-searching-for-help
Primary Care Collaborative (PCC). (2020). Multiple reports and survey results retrieved from https://www.pcpcc.org/

     CMS released another update 30 April 2020, impacting the delivery, coding, billing, and reimbursement of non-face-to-face care during the current PHE.  The document is 221 pages and, as always, it is recommended to refer to the source document.  Keep in mind that this information has not been finalized in the CFR and might have some slight edits by the time you see it in final form.
Voice-only visits (i.e. phone calls, no video) will receive higher reimbursements, backdated to March.  Providers should use telephone codes 99441 – 99443 for voice only E/M services for Medicare; these correspond to 99212 – 99214.  The full discussion begins on page 122.  This change does not mean you can bill a 99213 for a voice-only telehealth visit; you would use 99442 for the comparable time or MDM. 
       This modification was made for instances when the two-way, audio and video standard required for a Medicare telehealth service might not be available, CMS felt there could be “many circumstances where prolonged, audio-only communication between the practitioner and the patient could be clinically appropriate yet not fully replace a face-to-face visit.”
     CMS also posted information concerning selecting appropriate level for Medicare office / outpatient E/M visits furnished via telehealth; the discussion on time for E/M begins on page 135.  Level selection for these services when furnished via telehealth can be based on MDM or time. 
The IFC also addresses the impact of COVID-19 on Part C and Part D quality ratings, beginning on page 137.
Source:  https://www.cms.gov/files/document/covid-final-ifc.pdf