COVID-19 Billing and Payment Updates

April 24, 2020

GNYHA is writing to provide several COVID-19-related billing and payment updates.

Medicare 20% Add-On Payment

The Centers for Medicare & Medicaid Services (CMS) has released initial guidance on the implementation of Section 3710 of the CARES Act, which provides a 20% inpatient diagnosis-related group (DRG) bump for Medicare beneficiaries treated for COVID-19. The add-on payment will be applied to hospital claims billed under the inpatient prospective payment system. Because the 20% increase is applied to the DRG weight, it will flow-through the other payment add-ons such as the wage index, indirect medical education, and disproportionate share hospital adjustments.

The increase will be applied to claims that include the applicable COVID-19 ICD-10-CM diagnosis code (regardless of the final DRG assignment) and meet the date of service requirements, as follows:

The applicable COVID-19 ICD-10 code must be present on the claim to receive the additional payment. CMS has indicated claims billed on or before April 20 will be automatically reprocessed and claims received after April 20 will be paid at the increased rate. Providers should review their contracts with Medicare Advantage (MA) plans to determine whether the reimbursement rate increases may be extended to MA claims.

GNYHA has also requested that the New York State Medicaid program adopt a 20% increase for COVID-19 admissions.

Update on HHS CARES Act Provider Relief Fund

$50B General Distribution

Of the $100 billion provided in the CARES Act for the Provider Relief Fund, $50 billion is being distributed based on overall net patient revenue based on data from the 2018 Medicare cost reports. An initial $30 billion was distributed in recent weeks, and the remaining $20 billion will be distributed starting today.

Initial $30 Billion Distribution

Providers who have received a payment from the initial $30 billion distribution (based on each provider’s proportionate share of Medicare fee-for-service (FFS) payments) must sign an attestation agreeing to the terms and conditions within 30 days through the attestation portal. We have received several questions on the wording of the terms and conditions requiring providers to have treated COVID-19 patients. Please note that the Department of Health and Human Services (HHS) has stated the following on its website (emphasis added):

“If you ceased operation as a result of the COVID-19 pandemic, you are still eligible to receive funds so long as you provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19. Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19.”

Providers that do not have a direct deposit with United Health Group were expected to receive their payments on April 17. If you believe there is an error in your payment calculation or you have not received payment but believe you are eligible, please call the United Health Group hotline at 866-569-3522.

Additional $20B Distribution

HHS is distributing the remaining $20 billion of the $50 billion general distribution so that when it is added to the initial allocation, the entire $50 billion is allocated based on providers’ proportional shares of net patient revenue. Although these funds were distributed starting this morning, we await further guidance from HHS on the exact distributions.

Remaining Funds to be Distributed

The remaining $50 billion of the $100 billion provided in the CARES Act will be distributed to hospitals located in COVID-19 “hot spots” ($10 billion), rural providers ($10 billion), providers treating uninsured patients, and Indian Health Service facilities. An additional $75 billion for the Provider Relief Fund was included in recently passed legislation, but details on how it will be distributed are not yet available. Please see ML-68 for additional information.

GNYHA continues to advocate with the Trump Administration and HHS for priority funding for hospitals treating COVID-19 patients, and in Congress to increase the funding levels in the Provider Relief Fund for hospitals. GNYHA will keep members posted on developments on either of these fronts.

Medicare Accelerated Payments

National Government Services (NGS) has posted accelerated or advanced payment process FAQs and resources. NGS also has established a hotline number (888-802-3898) for providers to speak with representatives.

GNYHA continues to advocate for extending the current advance repayment timelines and reducing the applicable interest rate.

Medicaid Fee-For-Service Timely Filling

New York Medicaid has issued guidance on submitting claims that have exceeded timely filing limits. During the State of Emergency, claims exceeding the timely filing limits may be submitted electronically using Delay Reason 15 (Natural Disaster/State of Emergency). Additional documentation for Delay Reason 15 does not need to be sent at this time.

GNYHA has asked the New York State Department of Health to require that Medicaid managed care plans adopt this policy.

Antibody Testing

The American Medical Association (AMA) has created two new Common Procedural Technology codes (86328 and 86769) (the AMA guidance on the new codes is available here) for use as the industry standard for the reporting of COVID-19 antibody tests. These codes are effective April 10, but CMS has not yet issued guidance on the codes or established reimbursement rates. AMA also released a related Q&A document that details how to properly charge and bill.

Please contact Rebecca Ryan with any questions about the DRG increase or the CARES Act Provider Relief Fund and Matthew Felton with any questions on billing issues.