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Public Health Emergency Extension
Once again, the Department of Health and Human Services (HHS) has extended the PHE. The renewal went into effect on July 15, 2022, and it will be reconsidered again in October. Extensions can only be applied in 90-day increments.
As a reminder, the Consolidated Appropriations Act of 2022 states that all HHS/CMS waivers will continue to be in place for the duration of the PHE and an additional 151 days beyond that.
Recommendations for Telehealth and Commercial Plans
As we have touched on before, we are seeing commercial plans rejecting telehealth claims with a growing frequency. Commercial insurances may offer telehealth coverage as a selectable option within the plan, but that coverage is not guaranteed, like it generally was at the beginning of the pandemic. Each individual patient’s commercial coverage has the potential to be vastly different from the last, which may mean no coverage for audio-only telehealth specifically or potentially no virtual health coverage at all.
For months now, this has put a lot of pressure on providers to make frequent telehealth eligibility calls. It is a time-consuming process for many, and this is why it is now the recommendation of EMB that providers give this responsibility back to their patients. If telehealth is something that patients need to utilize, they can confirm with their own plans, prior to their next appointments. While learning the intricacies of one’s own medical coverage is meaningful in itself, it is also important for patients to be aware that any noncovered telehealth charges are their financial responsibility. It is advisable to have patients sign a document indicating that they understand they may be billed for virtual care, if telehealth is not one of their designated plan benefits. Please let EMB know if you would like a disclosure template for this.
Behavioral health continues to be the most commonly covered telehealth service with commercial plans and at in-person rates. However, EMB still recommends having these conversations with behavioral health patients so that they can have comprehensive knowledge of their coverage ahead of potential future policy changes.
What the “No Surprises Act” Means for Medical Debt
As a refresher, the No Surprises Act was recently established to target unexpected or “surprise” balance bills from air ambulance services and emergency or non-emergency care from out-of-network providers at in-network facilities. Under this, billing patients more than the established in-network cost-sharing amount is prohibited. This act, along with Regulation F, has altered credit reporting regulations that started going into effect in July. The changes impact all debt, including medical, and the new regulations have been provided by the Transunion, Equifax, and Experian credit agencies.
As of July 1, 2022, several items have taken effect:
- Medical debt collection accounts cannot be reported to credit bureaus until at least 365 days past the “Date of the First Delinquency”, and accounts that do not currently meet this requirement have been automatically deleted.
- Medical debt collection accounts reported as “paid” will be removed from credit histories, and this will be done automatically for future accounts reported as “paid”.
- Medical debt collection accounts should not be reported to the credit bureaus under the “pre-defined minimum threshold”. This amount will be at least $500 and will be determined in the coming months.
- Any medical debt collection account that does not meet the determined threshold will be deleted by the credit agencies.
Audit Reminder
As a reminder, there are many ongoing telehealth-specific audits, in particular from the Office of Inspector General. Every practitioner who has offered telehealth services during the PHE should anticipate this analysis of your records as a likely potential. There are more expected audits on the way, for all specialties.
Please reach out to EMB with any questions or concerns about maintaining best practice for telehealth record keeping or disclosures.
Coding Changes in 2023
The American Medical Association has released a proposal for significant changes to the evaluation and management (E/M) portion of CPT coding in 2023. Twenty-five E/M codes have been suggested for deletion, pending final approval from the proper channels. If these CPT codes are removed, there will be changes to coding for hospital observations, consultations, nursing facilities, resident services, and prolonged services.
If approved, these changes will affect how you report your encounters to EMB. Once we know more about the process, we will assist our providers through this transition. As decisions are finalized, EMB will monitor developments and provide updates.
General Updates
- Over the next few months, CMS will be initiating new Targeted Probe & Educate (TPE) reviews for Jurisdiction 5 providers. Selected providers can expect to receive a notification letter prior to the start of reviews.
- As a reminder, in accordance with the Continuing Appropriations Act, the 25% automatic recoupment rate for COVID-19 Accelerated and Advance Payment (CAAP) recovery will remain in place for the first 11 months of the recoupment period. After that time, the rate increases to 50% for 6 months. For example, if Medicare began recoupment on April 1, 2021, the rate will automatically increase to 50% on March 1, 2022.