PARAREV Weekly eJournal January 19, 2022

ej o u r n a l january 19, 2022

Public Health Emergency Extended NSA W ebinars

Answers To Your Questions

Complete COVID-19 Guide

Detailed Billing And Coding Guidance

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PARA Weekly eJournal: January 19, 2022

IPPS TRANSFER TO SWING BED

Q.

Can you please tell me how an IPPS DRG would be reimbursed if their patient was

admitted there for three days, and then transferred to our swing bed? Will the IPPS hospital have a reduced DRG reimbursement? Can you also please provide the CMS guideline?

A

. It depends on the Geometric Mean Length of Stay (GMLOS) of the DRG reported by the

discharging hospital. A three-day stay prior to discharge could very easily result in full DRG reimbursement if the GMLOS for that DRG was 4 or less.

The facility is paid a graduated per deim rate based on several factors as outlined in 42 Code of Federal Regulations. I?ve shared a link and some excerpts for your convenience.

42 CFR § 412.4 Discharges and transfers - Code of Federal Regulations (ecfr.io)

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PARA Weekly eJournal: January 19, 2022

IPPS TRANSFER TO SWING BED

Table 5, which indicates whether the DRG is a post-acute DRG, is available on the PARA Dat a Edit or Calcu lat or tab :

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PARA Weekly eJournal: January 19, 2022

IPPS TRANSFER TO SWING BED

Column D in Table 5 indicates whether the DRG is FY 2022 Post-Acute DRG, and column O shows FY 2022 GMLOS. The data in this screenshot is filtered to display only Post-Acute DRG?s and sorted by the GMLOS from lowest to highest.

Attached is an MLN and an FAQ on this topic. Please let us know if you need additional information or support.

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PARA Weekly eJournal: January 19, 2022

Up d at ed 1/ 12 / 2 2

2022 c o mp r eh en s i v e COV ID-19 Gu ide

Click an yw h er e on t h is page t o be t ak en t o t h e f u ll on lin e docu m en t .

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PARA Weekly eJournal: January 19, 2022

TUESDAY WEBINARS: COMPLYING WITH THE NO SURPRISES ACT

t ime is r unning out .

PARA exper t s ar e pr ovidin g a f r ee w ebin ar each Tu esday design ed t o h elp h ospit als u n der st an d an d com ply w it h t h e r equ ir em en t s u n der t h e No Su r pr ises Act .

Ever y Tu esday 11:30 am PST

Sign Up By Click in g HERE, Or Scan Th e QR Code

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PARA Weekly eJournal: January 19, 2022

DID YOU MISS IT? NO SURPRISES ACT WEBINARS? CATCH UP HERE! Did you miss t hev er y impor t ant "No Sur pr ises aCt " Webinar s and Q&A's? If you did you still have a chance to participate in the live versions (see previous page for links). And if you can't participate live, here are the links for the NSA Tool Demo Video , Webinars, Q&A sheets, and the Specific NSA Forms.

Our PARAREV team is always available to help.

Please reach out on our website.

DEM O -

NSA No Surprises Act Tool Demonstration Video

WEBINARS -

NSA No NSA No NSA No NSA No

Surprises Act Surprises Act Surprises Act Surprises Act

Update Webinar- 12/21/21 Update Webinar- 12/28/21 Update Webinar- 1/04/22 Update Webinar- 1/11/22

Q&A -

NSA No Surprises Act Update Q & A? 12/21/21 NSA No Surprises Act Update Q & A? 12/28/21 NSA No Surprises Act Update Q & A? 1/11/22

FORM S -

PARA - NSA Template for Convening Facility or Provider Good Faith Estimate - updated 12.28.21 PARA - NSA Template for Right to Receive a Good Faith Estimate of Expected Charges - updated 12.28.21 PARA - NSA Template for Disclosure Notice - updated 12.28.21

LOGINS - If you already have a PDE login ? you have access to the NSA Tool by logging into the PDE and clicking on the PTT/NSA Tab and NSA Link Tab - The Generic Log-Ins are available ? Please reach out to your Account Executive for more details.

- The Generic log-in providedexpir es on Jan u ar y 31, 2022, due to CPT® license agreement with the AMA. - You will need to create an individual account for those who will be creating Estimates.

- Please have your Administrator fill out this FORM to designate your facilities Primary Contact(s) for the NSA Project so we can create a user ID for them.

- Please make sure we have an updated email address for you ? Fill out this FORM to confirm your email and to be added/updated onto the Distribution List.

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PARA Weekly eJournal: January 19, 2022

STATE-LEVEL ENFORCEMENT OF NO SURPRISES ACT

The No Surprises Act (NSA) is a set of laws within the Consolidated Appropriations Act of 2021, which offers certain protections for patients against ?surprise? medical bills. The law prohibits facilities and other providers from ?balance billing? patients in certain situations, and the regulations require facilities to offer uninsured (or self-pay) patients a ?Good Faith Estimate? of charges in advance of services.In addition, facilities and certain providers are required to provide patients with a standard Disclosure notice which informs the patient about these protections under state and federal law.

State agencies are partially responsible for enforcement of provider compliance with the NSA rules.Since the regulations became effective on 1/1/2022, CMS surveyed states to determine the state?s authority and intention to enforce new provisions of the NSA. CMS has published state-specific letters which provide details on NSA enforcement at the state level and how the federal dispute resolution processes compare with existing state processes.The state-specific letter can be found on the CMS website at the link below: Consolidated Appropriations Act, 2021 (CAA) | CMS

Information in the state letters may be useful in preparing the NSA Disclosure notice, particularly as it pertains to state enforcement authorities.Providers are encouraged to check back frequently if your state is not yet listed ? state letters will continue to be added as the information is gathered

by CMS.

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PARA Weekly eJournal: January 19, 2022

UPCOMING "ASK THE CONTRACTOR" TELECONFERENCES Q1, 2022

Most Part A and B Medicare Administrative Contractors offer ?Ask the Contractor ? (ATC) teleconferences to provide hospitals and other providers an opportunity to ask questions about Medicare policies and procedures.

Some MACs permit providers to submit questions to their Medicare Administrative Contractor in advance.

Each MAC may hold separate ATC teleconferences for Part A, Part B, and DME suppliers; furthermore, each MAC mayfocus on certain topics during each ATC webinar.Not all MACs follow the same format.

Her e ar e dat es an d lin k s f or u pcom in g ATC con f er en ces f or Par t A M ACs: WPS Ju r isdict ion 5 - Iowa, Kansas, Missouri, and Nebraska - Next ATC 1/25/2022 - Topic:Outpatient Rehabilitation Updates http://wpsghalearningcenter.com/confirm-course?courseid=AM2awu6Lzvg1 NGS Ju r isdict ion 6 an d K - J6: Illinois, Minnesota, and Wisconsin; - JK: Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont - Last meeting held 12/16/2021 https://www.ngsmedicare.com/web/ngs/-/ af_ask-the-contractor-teleconference_091421?lob=93617&state=97206&region=93624 - 2022 ATC conferences have not yet been announced WPS - Ju r isdict ion 8 - Indiana and Michigan - Past ATC conference recordings are available, but 2022 session schedule not yet announced WPS J8 Part A Training Guides and Resources Nor idian Ju r isdict ion E - M edicar e Par t A - California, Hawaii, Nevada, American Samoa, Guam, Northern Mariana Islands - Next ATC March 23, 2022 https://med.noridianmedicare.com/web/jea/education/act 9

PARA Weekly eJournal: January 19, 2022

UPCOMING "ASK THE CONTRACTOR" TELECONFERENCES Q1, 2022

Nor idian Ju r isdict ion F - Alaska, Arizona, Idaho, Montana, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming - Next ATC March 23, 2022 https://med.noridianmedicare.com/web/jfa/education/act Novit as Ju r isdict ion H - Arkansas, Colorado, Louisiana, Mississippi, New Mexico, Oklahoma, Texas, Indian Health & Veteran Affairs - Next ATC scheduled for February 23, 2022 - Topics will include Novitas Initiatives, Acute Hospital Provider Liable Billing, and Acute Hospital Outpatient Billing https://www.novitas-solutions.com/webcenter/portal/MedicareJH/pagebyid?contentId=00008196 Palm et t o - Ju r isdict ion J - Alabama, Georgia, and Tennessee - January 12, 2022; April 13, 2022 https://palmettogba.com/palmetto/jja.nsf/DID/AU9QTU8307 Novit as Ju r isdicat ion L - Delaware, District of Columbia, Maryland, New Jersey and Pennsylvania - Next ATC February 23, 2022 - Topics will include Novitas Initiatives, Acute Hospital Provider Liable Billing, and Acute Hospital Outpatient Billing https://www.novitas-solutions.com/webcenter/portal/MedicareJH/pagebyid?contentId=00008196 Palm et t o - Ju r isdict ion M - North Carolina, South Carolina, Virginia, and West Virginia - Next ATC January 12, 2022; April 13, 2022 https://palmettogba.com/palmetto/jma.nsf/DID/89BJAR3017 Fir st Coast Ser vice Opt ion s - Ju r isdict ion N - Search for ?Ask the Contractor ? found no results https://medicare.fcso.com/FAQs/0453634.asp

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PARA Weekly eJournal: January 19, 2022

COVID-19 NEW HCPCS FOR REMDISIVIR IN OUTPATIENT SETTING

In its January 7, 2022, Special Edition MLN CMS announces a code assignment of J0248 for Veklury (remdesivir) antiviral medication for outpatient treatment of Covid-19. The code is effective for dates of service on or after December 23, 2021. https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider -partnership-email-archive/2022-01-07-mlnc-se

J0248?

- Long descriptor: Injection, remdesivir, 1 mg - Short descriptor: Inj, remdesivir, 1 mg Providers should refer to their Medicare Administrative Contractors (MACS) that will determine Medicare coverage and payment.

CMS created the new HCPCS code following the recent statement from the National Institutes of Health (NIH) COVID-19 Treatment Guidelines Panel regarding therapy for the COVID-19 Omicron variant: https://www.covid19treatmentguidelines.nih.gov/therapies/antiviral-therapy/remdesivir/

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PARA Weekly eJournal: January 19, 2022

PUBLIC HEALTH EMERGENCY EXTENDED TO APRIL 16, 2022

As ex pect ed,

Health and Human Services Secretary Xavier Becerra extended

the COVID-19 Public Health Emergency for an additional 90 days on January 16, 2022.

This extension will end on 4/16/2022. https://aspr.hhs.gov/legal/PHE/Pages/COVID19-14Jan2022.aspx

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PARA Weekly eJournal: January 19, 2022

AUDIO-ONLY TELEHEALTH CODING FOR 2022

Ef f ect iv eJanuar y 1, 2022, physicians and qualified health care providers who render telehealth services through audio-only real-time telecommunications may append m odif ier 93 to the CPT® on the professional fee claim. The instruction was provided by the American Medical Association: https://www.ama-assn.org/system/files/ cpt-appendix-a-modifier-93.pdf

CMS updated the telehealth services list on November 1, 2021. It is available as a download from the link below. Column D, ?Can Audio-only Interaction Meet the Requirements?? identifies those services with a ?Yes.?At the time of publication, Medicare has not indicated modifier 93 is required.

https://www.cms.gov/Medicare/Medicare-general-information/telehealth/telehealth-codes

Further instruction from Medicare is expected in the coming weeks.When it is available, Par aRev will publish an update to this paper.

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PARA Weekly eJournal: January 19, 2022

2022 REQUIREMENTS FOR NO SURPRISES ACT

The No Sur pr ises Act (NSA) is a f eder al l aw which goes int o ef f ect on Januar y 1, 2022.

The Department of Health and Human Services (HHS) has realized that not all aspects of the NSA will be able to be implemented by providers and facilities by January 1, 2022, so they have elected to exercise?enforcement discretion? on portions of the act in 2022. To be in compliance in 2022, health care providers and health care facilities must be prepared to: - 1Publicize and disseminate a ?Disclosure Notice? which informs patients of their rights under the No Surprises Act; and - Publicize and disseminate a ?Right to Receive a Good Faith Estimate? to uninsured or self-pay patients; and - Provide uninsured or self-pay patients with a good faith estimate (within a $400 threshold) of services that will be billed by the ?convening? provider or facility.

- Present a Notice and Consent form, with an estimate of charges, to a patient with a group health plan who chooses to receive services from an out-of-network facility or provider and submit a claim to the health plan.

Disclosu r e Not ice: By January 1, 2022, the disclosure notice must be prominently displayed on websites, in public areas of an office or facility, and on a one-page (double-sided) notice provided in-person or through mail or e-mail, as chosen by the patient. The disclosure notice must be provided to all commercially insured patients after January 1, 2022, or before that date if the elective service will be provided after January 1, 2022. The notice must be provided before requesting a payment from the insured or before a claim is submitted on behalf of the insured.

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PARA Weekly eJournal: January 19, 2022

2022 REQUIREMENTS FOR NO SURPRISES ACT

eCFR :: 45 CFR Part 149 -- Surprise Billing and Transparency Requirements

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PARA Weekly eJournal: January 19, 2022

2022 REQUIREMENTS FOR NO SURPRISES ACT

In states where there are state laws that protect patients against surprise billing, providers and facilities can use a state disclosure notice if it meets or exceeds the federal guidelines. If a provider or facility drafts their own disclosure notice it must include these three points: - Restrictions on providers and facilities regarding balance billing in certain circumstances - Any applicable state laws protecting against balance billing - Contact information for appropriate state and federal agencies if the individual believes their right have been violated Righ t t o Receive a Good Fait h Est im at e Not ice: All uninsured or self-pay individuals must be made aware, both orally and in writing, of their right to receive a good faith estimate for any services that will be rendered beginning January 1, 2022.

The form must be prominently displayed on websites, in offices, and where scheduling or questions about the cost of health care may occur.

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PARA Weekly eJournal: January 19, 2022

2022 REQUIREMENTS FOR NO SURPRISES ACT

Good Fait h Est im at es t o Un in su r ed/ Self Pay When discussing the good faith estimate it is important to know a few terms.

- A h ealt h car e pr ovider (pr ovider ) is defined as a physician or other health care provider who is acting within the scope of practice of that provider ?s license or certification under applicable State law - A h ealt h car e f acilit y (f acilit y) is defined as a hospital or hospital outpatient department, critical access hospital, ambulatory surgical center, rural health center, federally qualified health center, laboratory, or imaging center that is licensed as an institution pursuant to State laws or is approved by the agency of such State or locality responsible for licensing such institution as meeting the standards established for such licensing - The con ven in g pr ovider or f acilit yi s the one who receives the initial request for a good faith estimate from an uninsured or self-pay individual and who is or, in the case of a request, would be responsible for scheduling the primary item or service -

A co-pr ovider or co-f acilit y furnishes items or services that are customarily provided in conjunction with the convening provider.

An uninsured patient is an individual who does not have benefits for an item or service under a group health plan; whereas a self-pay patient is an individual who has benefits under a group health plan but chooses not to have a claim submitted to their plan. The good faith estimate presented to an uninsured or self-pay patient must include services reasonably expected to be provided by the convening provider or facility. At t h is t im e, est im at es f or ser vices pr ovided by co-pr ovider s an d co-f acilit ies do n ot h ave t o be pr ovided by t h e con ven in g pr ovider or f acilit y.

The following list is provided in the interim final rule published in the Code of Federal Regulations.

CMS followed up with a Fact Sheet that clarifies HHS will not be enforcing the requirement of including services provided by co-providers or co-facilities.

A good faith estimate must include: - Patient name and date of birth - Description of the primary item or service - Itemized list of items or services reasonably expected to be furnished - Items or services reasonably expected to be furnished by the convening provider or convening facility for the period of care; and - Items or services reasonably expected to be furnished by co-providers or co-facilities 17

PARA Weekly eJournal: January 19, 2022

2022 REQUIREMENTS FOR NO SURPRISES ACT

- Applicable diagnosis codes, expected service codes, and expected charges associated with each listed item or service - Name, National Provider Identifier, and Tax Identification Number of each provider or facility represented in the good faith estimate, and the State(s) and office or facility location(s) where the items or services are expected to be furnished by such provider or facility - List of items or services that the convening provider or convening facility anticipates will require separate scheduling

eCFR :: 45 CFR Part 149 -- Surprise Billing and Transparency Requirements

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PARA Weekly eJournal: January 19, 2022

2022 REQUIREMENTS FOR NO SURPRISES ACT

Requirements Related to Surprise Billing; Part II Interim Final Rule with Comment Period | CMS

The Good Faith Estimate process that requires facilities and providers to transmit estimates to health plans, is still on hold.

Not ice an d Con sen t The Notice and Consent is being enforced for those rare instances when the patient has a choice of providers and chooses to receive services from an out-of-network facility or provider. In the instance when a patient chooses to receive services from an out-of-network facility, that signed consent to waive balance billing protections will cover all co-providers within that facility.

Situations when a patient does not have a choice of providers and cannot be requested to sign a consent waiving their balance billing protections in an in-network facility are: - When receiving services that are considered ancillary services: - Items and services related to emergency medicine, anesthesiology, pathology, radiology, and neonatology - Items and services provided by assistant surgeons, hospitalists, and intensivists - diagnostic services, including radiology and laboratory services - Items and services provided by a nonparticipating provider if there is no participating provider who can furnish such item or service at such facility

Balance billing is prohibited in all emergency situations, even those that arise during a service that is being provided under a written consent. Any charges related to that emergency cannot be balance billed until the patient is deemed stable, as defined in the NSA ? able to transport to another facility by non-medical transportation. In the event the patient requires a higher level of care that requires transport, the EMTALA guidelines take precedence.

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PARA Weekly eJournal: January 19, 2022

2022 REQUIREMENTS FOR NO SURPRISES ACT

A patient admitted to an out-of-network facility from an emergency department who is then considered stable, must be presented with a notice and consent before transferring to an in-network facility. If the consent is signed, the out-of-network facility can balance bill for charges incurred after the provider documents that patient is stable, as defined in the NSA--able to transport to another facility by non-medical transportation. Ancillary services cannot balance bill even after the patient is considered stable. eCFR :: 45 CFR Part 149 Subpart E -- Health Care Provider, Health Care Facility, and Air Ambulance Service Provider Requirements

The Notice and Consent form, with an estimate of all charges, must be presented to the patient for a signature. This form must be available in the 15 most common languages in the geographical area. If the individual?s preferred language is not among those 15, a qualified interpreter must be made available to assist the patient with understanding their rights. The form must be provided at least 72 hours prior to scheduled services, when they are scheduled at least 72 hours out. When services are scheduled and performed on the same day, the document is required to be presented at least 3 hours before the services are rendered. The patient must be provided with a signed copy and a signed copy must be maintained in the medical record in the same manner as all other required documented.

PARAREV has an online tool that can assist with estimates and notices. Contact us at 800-999-3332 and ask to speak with an Account Executive for more information.

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PARA Weekly eJournal: January 19, 2022

CM S h as pu blish ed a n ew book let det ailin g n ew ch an ges f or 2022 f or Ru r al Healt h Clin ics.

You can dow n load t h e book let h er e by click in g an yw h er e on t h e gr aph ic.

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PARA Weekly eJournal: January 19, 2022

Neul ast a is an ex pensiv e, separ at ely- payabl e dr ug under OPPS. In 2022, Medicare changed the HCPCS code, which included a change to the units billed for the 6 milligram vial.Hospitals and clinics which bill for Neulasta should pay particular attention to both the change in HCPCS and the unit of measure for the new code, as the units will drive reimbursement under OPPS. Effective January 1, 2022, Medicare deleted HCPCS J2505:

The following new code will replace the deleted code:

Providers of Neulasta (pegfilgrastim) who have customarily billed one unit for a 6 milligram dose should pay careful attention to the new unit of measure ?sin ce t h e n ew HCPCS J2506 r epor t s on ly 0.5 m g., pr ovider s w ill n eed t o r epor t 12 u n it s f or t h e equ ivalen t dose u sin g t h e n ew code.

Neulasta (pegfilgrastim) is a separately payable drug; Medicare reimbursement in 2021 for a 6 mg. dose is set at $2,221.63 in the fourth quarter of 2021.

More information regarding the decision to update to the new HCPCS is available on pages 16 and 17 of the document at the following hyperlink: https://www.cms.gov/files/document/2021-hcpcs-application-summary-bi-annual-1-2021 -non-drug-and-non-biological-items-and-services.pdf

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PARA Weekly eJournal: January 19, 2022

THE TOP 10 ISSUES FACING HOSPITALS IN 2022

1

2

pricetransparency.

l abpamareporting.

The back-end work is complex. The data requirements are enormous. And making a user-friendly and informative portal is daunting.

Medicare extended the deadline for certain hospitals and clinics which meet the description of an ?Applicable Laboratory? to report private payer lab rates to the first quarter of 2023.

Hospitals will require expert technical assistance. There will be a cost, but the cost of non-compliance outweighs the initial investment.

It's a reprieve--for now. But knowing if you're one of those certain hospitals or clinics may require expert help.

3

4

Nosurprisesact.

appropriateusecriteria.

While providers and medical associations are voicing their disappointment in the NSA arbitration process, they are generally supportive of the NSA. That being said, implementing the requirement will continue to be a priority for hospitals.

Medicare moved the deadline for OPPS hospitals and interpreting radiologists to comply with reporting requirements to January 1, 2023. But that doesn't mean hospitals can rest.

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Work throughout 2022 will be required in order to comply with these requirements.

PARA Weekly eJournal: January 19, 2022

THE TOP 10 ISSUES FACING HOSPITALS IN 2022

5

6

staffingchal l enges.

administrativecosts.

The inability to adequately achieve a full cadre of qualified revenue cycle employees directly impacts a hospital's cash flow and financial performance.

Keeping the doors open will continue to drain resources and reserves as hospitals face rapidly rising administrative costs.

This, in turn places immense pressure on capital and operational needs.

The challenge for hospitals will be in finding ways to stem the tide of rising costs and potential red ink.

7

8

ARrecovery &resol ution.

cl aimdenial management.

Exacerbated by staffing shortages, pursuing aging, small-balance claims will most likely gain better success by using a dedicated, specialized team ensure quicker cash conversion and a reduction of bad debt reserves.

Hospitals will need to increase their reliance on intelligent automation and staff specialization in order to efficiently process all claims, regardless of size or age, for hospitals.

This will contribute to cash flow and improved operational management.

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PARA Weekly eJournal: January 19, 2022

THE TOP 10 ISSUES FACING HOSPITALS IN 2022

9

10

Invoice&Payment processing.

improvingthepatient experience.

Medical practices--whether hospital-owned or independent--cite patient collections as a top revenue cycle struggle.

Healthcare organizations face tough competition in attracting and retaining patients who demand and experience that matches the level of customer service they expect from other consumer experiences..

Providers are now challenged to create invoicing and payment systems that are easy for patients to use and that offer a variety of payment options.

For organizations offering a variety of services in different locations, it becomes even more challenging to provide accurate and up-to-date information from one centralized database.

Providers are also required to follow strict guidelines to protect patient information, making it even more difficult to create a patient-friendly portal that encourages users to pay in a timely manner.

Here is where the patient portal becomes either most valuable, or most challenging.

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PARA Weekly eJournal: January 19, 2022

MEDICARE TO PRIORITIZE RURAL EMERGENCY HOSPITAL RULES

Sect ion 125 of t heConsol idat ed Appr opr iat ions Act of 2021(CAA) cr eat ed t he Rur al Emer gency Hospit al (REH) model as a new Medicar epr ov ider t y pe.

This new provider type will be eligible for enhanced Medicare fee-for-service rates at 5% above OPPS rates, plus an ?Additional Facility Payment? (AFP) designed to bolster the financial viability of providing emergency care in rural areas.The designation is effective as of January 1, 2023.

Current Critical Access Hospitals (CAHs) and rural Prospective Payment System (PPS) hospitals with fewer than 50 beds may convert to REH status to furnish certain outpatient hospital services in rural areas, including emergency department and observation services, but an REH may not offer acute care inpatient services. An REH may offer non-emergency outpatient services and subacute skilled nursing care, however.

New requirements for ?Rural Emergency Hospitals? are among the priorities discussed in the Department of Health and Human Services (HHS) Regulatory Plan for Fiscal Year 2022.A link and an excerpt are provided below: https://www.reginfo.gov/public/jsp/eAgenda/StaticContent/202110/Statement_0900_HHS.pdf The Department also plans to issue a proposed rule on Requirements for Rural Emergency Hospitals. This rule would establish health and safety requirements as Conditions of Participation (CoPs) for Rural Emergency Hospitals (REHs) participating in Medicare or Medicaid, in accordance with Section 125 of the Consolidated Appropriations Act, 2021, and will establish payment policies and payment rates for REHs. This rule will aim to address barriers to health care, unmet social needs, and other health challenges and risks faced by rural communities.

Excerpts from the Consolidated Appropriations Act are provided below: https://www.congress.gov/116/bills/hr133/BILLS-116hr133enr.pdf? Beginning on page 1779 ?(2) RURAL EMERGENCY HOSPITAL.? The term ?rural emergency hospital?means a facility described in paragraph (3) that?

(A) is enrolled under section 1866(j), submits the additional information described in paragraph (4)(A) for purposes of such enrollment, and makes the detailed transition plan described in clause (i) of such paragraph available to the public, in a form and manner determined appropriate by the Secretary;(B) does not provide any acute care inpatient services, other than those described in paragraph (6)(A); 26

PARA Weekly eJournal: January 19, 2022

MEDICARE TO PRIORITIZE RURAL EMERGENCY HOSPITAL RULES

?

(6) DISCRETIONARY AUTHORITY.? A rural emergency hospital may?

(A) include a unit of the facility that is a distinct part licensed as a skilled nursing facility to furnish post-hospital extended care services; and (B) be considered a hospital with less than 50 beds for purposes of the exception to the payment limit for rural health clinics under section 1833(f).

Interested readers may wish to review a summary of the new provider type prepared by the National Rural Health Association at the following link: https://www.ruralhealth.us/NRHA/media/Emerge_NRHA/Advocacy/ Government%20affairs/2021/04-15-21-NRHA-Rural-Emergency-Hospital-overview.pdf

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PARA Weekly eJournal: January 19, 2022

FDA ISSUES EUAS FOR ANTIVIRAL PILLS TO TREAT COVID-19 AT HOME

On December 23, 2021, t heFood and Dr ug Administ r at ion appr ov ed emer gency useaut hor izat ion (EUA) f or Mer ck Mol nupir av ir pil l for the treatment of COVID-19.The drug is cleared for patients 18 and older who test positive for COVID-19 and are at high risk of hospitalization or death.The treatment course includes four capsules every 12 hours for 5 days beginning as soon as the patient tests positive for COVID-19 and within five days of exhibiting symptoms.

The FDA cautions that the capsules are not approved for patients under 18 nor pregnant women due to potential birth defects and the effects on bone and cartilage growth. An FDA fact sheet for molnupiravir is available through the following link: https://www.fda.gov/media/155054/download

The Molnupiravir EUA follows just behind the December 22, 2021, announcement that the FDA authorized an EUA for Pfizer drug, Paxlovid? for high-risk patients age 12 and older who test positive for COVID-19. The 5-day Paxlovid? treatment course includes two drugs, two n ir m at r elvir tablets and one r it on avir tablet twice a day. Similar to the requirements for the molnupiravir treatment, paxlovid should be taken as soon as the patient has tested positive for COVID-19 and within five days of exhibiting symptoms.

The FDA published a fact sheet for Paxlovid? at the following link: https://www.fda.gov/media/155050/download

These prescription drugs are for at-home use, so they will not typically be charged on a hospital or professional fee claim form. There are no HCPCS codes assigned to describe these medications at this time.

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PARA Weekly eJournal: January 19, 2022

COVID VACCINE AND MONOCLONAL ANTIBODY BILLING TO MA PLANS

Or iginal Medicar e t r ansf er r ed r esponsibil it y f or Cov id- 19 vaccines and Cov id- 19 monocl onal ant ibody t her apy r eimbur sement t o Medicar e Advant age pl ans beginning Januar y 1, 2022.

Previously, Medicare required providers to report these services for Medicare Advantage patients to original Medicare for payment. https://www.cms.gov/medicare/ covid-19/medicare-billingcovid-19-vaccine-shot-administration

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PARA Weekly eJournal: January 19, 2022

COVID VACCINE AND MONOCLONAL ANTIBODY BILLING TO MA PLANS

Medicare instructs providers on the Monoclonal Antibody therapy through the following link: https://www.cms.gov/medicare/covid-19/monoclonal-antibody-covid-19-infusion

PARAREV offers a full list of the Covid-19 monoclonals and administration codes through the following link: https://apps.para-hcfs.com/para/Documents/New%20COVID-19%20Monoclonal %20Administration%20Codes.pdf

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PARA Weekly eJournal: January 19, 2022

DEBT LIMIT BILL BRINGS RELIEF FOR MEDICARE PROVIDERS

The United States Congress passed a bill on December 9, 2021 which enables the Senate to use special expedited procedures to increase the debt limit.

Additional provisions of the bill make changes to several important issues for Medicare providers.

The text of the bill is available at the link below: https://www.congress.gov/bill/117th-congress/senate-bill/610/actions

The new law enacts the following changes for Medicare providers: - Ext en ds t h e m or at or iu m of t h e u su al 2% sequ est r at ion discou n t applied to Medicare payments until March 31, 2022, and reduces the discount on Medicare payments from 2% to 1% for three months, until June 30, 2022 - Ext en ds a M edicar e Ph ysician Fee Sch edu le paym en t in cr ease through calendar 2022; 31

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DEBT LIMIT BILL BRINGS RELIEF FOR MEDICARE PROVIDERS

- St ops f u r t h er r edu ct ion s t o t h e Clin ical Lab Fee Sch edu le in 2022 through 2025; - Avoids a 15% Cu t t o CLFS paym en t r at es f or m an y com m on lab t est s which was to become effective 1/1/2022, as part of the phase-in of rates developed from data collected in 2016 - Delays t h e Pr ivat e Payer lab r at e r epor t in g deadlin e for the January-June 2019 period another year to be due the first quarter of 2023; - Delays t h e im plem en t at ion of M edicar e?s Radiat ion On cology M odel until 2023 Salient excerpts of the changes to Medicare laws and regulations pertaining are provided on the following pages.New language is provided in highlighted italics.

Sequ est r at ion?changes to 2 USC 901a Enforcement of budget goal: (6) Implementing direct spending reductions ?

(B) On the dates OMB issues its sequestration preview reports for each of fiscal years 2022 through 2030, pursuant to section 904(c) of this title, the President shall order a sequestration, effective upon issuance such that(C) Notwithstanding the 2 percent limit specified in subparagraph (A) for payments for the Medicare programs specified in section 256(d), the sequestration order of the President under such subparagraph for fiscal year 2022 shall be applied to such payments so that with respect to the period beginning on April 1, 2022, and ending on June 30, 2022, the payment reduction shall be 1.0 percent. ?(D) Notwithstanding the 2 percent limit specified in subparagraph (A) for payments for the Medicare programs specified in section 256(d), the sequestration order of the President under such subparagraph for fiscal year 2030 shall be applied to such payments so that? ?(i) with respect to the first 6 months in which such order is effective for such fiscal year, the payment reduction shall be 2.25 percent; and?(ii) with respect to the second 6 months in which such order is so effective for such fiscal year, the payment reduction shall be 3 percent.

Th e M edicar e Ph ysician Fee Sch edu le- (Changes to TITLE 42 / CHAPTER 7 / SUBCHAPTER XVIII / Part B / § 1395w-4) (t) Supporting physicians and other professionals in adjusting to Medicare payment changes during 2021 2021 or 2022

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(1) In general In order to support physicians and other professionals in adjusting to changes in payment for physicians' services during 2021 during 2021 and 2022, the Secretary shall increase fee schedules under subsection (b) that establish payment amounts for such services furnished on or after January 1, 2021, and before January 1, 2022, by 3.75 percent for (A) such services furnished on or after January 1, 2021, and before January 1, 2022, by 3.75 percent; and (B) such services furnished on or after January 1, 2022, and before January 1, 2023, by 3.0 percent.

Clin ical Lab Fee Sch edu le? changes to TITLE 42 / CHAPTER 7 / SUBCHAPTER XVIII / Part B / § 1395m-1 revising the phase-in of reductions that would have reduced CLFS rates on many codes by as much as 15% in 2022: - (b) Payment rates for clinical diagnostic laboratory tests - ?

(3) Phase-in of reductions from private payer rate implementation (A) In general Payment amounts determined under this subsection for a clinical diagnostic laboratory test for each of 2017 through 2024 through 2025 shall not result in a reduction in payments for a clinical diagnostic laboratory test for the year of greater than the applicable percent (as defined in subparagraph (B)) of the amount of payment for the test for the preceding year.

(B) Applicable percent defined In this paragraph, the term "applicable percent" means(i) for each of 2017 through 2020, 10 percent; (ii) for2021 for each of 2021 and 2022, 0 percent; and (iii) for each of 2022 through 2024 2023 through 2025, 15 percent.

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Lab PAM A r epor t in g-(Changes to 42USC 1395m-1(a)(1)(B) Improving policies for clinical diagnostic laboratory tests) (B) Revised r epor t in g per iod ·In the case of reporting with respect to clinical diagnostic laboratory tests that are not advanced diagnostic laboratory tests, the Secretary shall revise the reporting period under subparagraph (A) such that(i) no reporting is required during the period beginning January 1, 2020, and ending December 31, 2021 December 31, 2022; (ii) reporting is required during the period beginning January 1, 2022 January 31, 2023, and ending March 31, 2022 March 31, 2023; and (iii) reporting is required every three years after the period described in clause (ii).

Th e Radiat ion On cology pr ogr am -(Changes to the December 27, 2020 Consolidated Appropriations Act, Public Law 116-26): SEC. 133. DELAY TO THE IM PLEM ENTATION OF THE RADIATION ONCOLOGY M ODEL UNDER THE M EDICARE PROGRAM . Notwithstanding any provision of section 1115A of the Social Security Act

(42 U.S.C. 1315a), the Secretary of Health and Human Services may not implement the radiation oncology model described in the rule entitled ??Medicare Program; Specialty Care Models To Improve Quality of Care and Reduce Expenditures??(85 Fed. Reg. 61114 et seq.), or any substantially similar model, pursuant to such section before January 1, 2022 January 1, 2023.

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Th u r sday, Jan u ar y 13, 2022

New s -

COVID-19: Updated Materials for Visiting Nursing Homes During Omicron Surge COVID-19: Vaccine Access in Long-term Care Settings COVID-19: New HCPCS Code for Remdesivir Antiviral Medication ? Updated NIH Treatment Guidelines Panel Link COVID-19: Pfizer Booster Doses for Ages 12+ & Immunocompromised Ages 5?11 CMS Proposes Medicare Coverage Policy for Monoclonal Antibodies Directed Against Amyloid for the Treatment of Alzheimer ?s Disease & National Stakeholder Call Additional Residency Positions: Apply by March 31 Medicare Ground Ambulance Data Collection System: Updated Documents DMEPOS Requirement Updates Effective April 13 RHC: AIR Payment Limit for CY 2022 Non-Medical Factors Can Affect Patient Health

Com plian ce -

DMEPOS Items: Documenting Medical Records

Claim s, Pr icer s, & Codes -

DMEPOS: Accreditation Claims Edits

Even t s -

National Stakeholder Call with the CMS Administrator ? January 18

Pu blicat ion s -

Clinical Lab Fee Schedule ? Revised

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