In response to COVID-19, CMS has published updated FAQs in order to provide flexibility to states and providers in how they administer and utilize Medicaid and the Children's Health Insurance Program ("CHIP"). While these FAQs are directed toward state agencies, we have created a list of provider-focused takeaways to inform you about some of the changes taking place for state agencies.
- Testing will typically be covered. The test
for the detection of COVID-19 is covered under Medicaid's
mandatory laboratory benefit as described at 1905(a)(3) of the Social Security Act and 42 C.F.R. § 440.30. However, if testing
procedures do not meet those criteria, the test may still be
covered under the optional diagnostic benefit as described at 1905(a)(13) of the Social Security Act and 42 C.F.R. § 440.130(a).
Check to see if your state's current Medicaid cost-sharing policies include cost-sharing for the COVID-19 detection test. States have a variety of options to change cost-sharing requirements during public health emergencies. If a provider decides to waive cost-sharing, that provider may be less likely to be subject to any enforcement action by HHS.
- Health care workers can be utilized more flexibly than
under normal circumstances. States have substantial
authority to respond to issues relating to shortages of health care
workers. Check your state's Medicaid agency for changes to the
types of providers authorized to deliver various services and for
changes in required provider qualifications.
For example, some state Medicaid programs are issuing FAQs, which provide guidance on how providers may deliver and bill for services during the COVID-19 outbreak.
- Review your capabilities to provide telemedicine
services. Both Federally Qualified Health Centers
("FQHCs") and Rural Health Centers ("RHCs") are
eligible to provide more flexible telemedicine during a declared
state of emergency. Your state may have to amend its current state
plan; however, options are in place for states to expedite this
process, and many states have already done so.
- Reimbursements will be lower if you are utilizing
federal health care workers. During a declared state
of an emergency, and where healthcare facilities face critical
staffing shortages, providers (in some circumstances) have the
ability to utilize federal health care workers. This creates
billing complications for reimbursement, as your state agency will
not receive federal financial participation for costs associated
with those federal workers.
- CMS has released COVID-19 specific billing codes.
CMS developed U0001, a code specifically for CDC
testing laboratories to test patients for COVID-19. CMS recently
added U0002, which allows laboratories to bill for non-CDC lab
tests for COVID-19. These codes will begin being accepted starting
on April 1, 2020 for dates of service on or after February 4, 2020.
For additional guidance on specific billing codes, check
our Telemedicine billing toolkit.
- Review CMS guidance. CMS has released a disaster response toolkit that provides additional information and guidance to help inform Medicaid providers' responses to COVID-19.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.