In response to concerns from providers and association representatives, CMS published a Q&A page about its plans to return to pre-pandemic regulations and routines.
On March 30, CMS suspended most Medicare Fee-For-Service medical reviews because of the COVID-19 pandemic. This included pre-payment medical reviews conducted by Medicare Administrative Contractors under the Targeted Probe and Educate program, and post-payment reviews conducted by MACs, Supplemental Medical Review Contractor reviews, and Recovery Audit Contractor (RAC).
As states reopen, and given the importance of medical review activities to CMS' program integrity efforts, CMS expects to discontinue exercising enforcement discretion beginning on August 3, 2020, regardless of the status of the public health emergency.
If selected for review, providers should discuss with their contractor any COVID-19-related hardships they are experiencing that could affect audit response timeliness. CMS notes that all reviews will be conducted in accordance with statutory and regulatory provisions, as well as related billing and coding requirements. Waivers and flexibilities in place at the time of the dates of service of any claims potentially selected for review will also be applied.
Effective March 29, 2020, certain claims processing for the Review Choice Demonstration for Home Health Services were paused in Illinois, Ohio, and Texas, because of the COVID-19 pandemic. During the pause, home health claims submitted on or after March 29, 2020 were not subject to the review choices made by home health agencies under the demonstration. However, the MAC continued to review any pre-claim review requests that were submitted.
Given the importance of prior authorization activities to CMS' program integrity efforts, CMS expects to discontinue exercising enforcement discretion beginning on August 3, 2020, regardless of the status of the public health emergency.
CMS will resume demonstration operations in all states.
The Home Health demonstration is currently scheduled to end on May 31, 2024. At this time, CMS is not planning an extension beyond May 31, 2024 to accommodate the delay caused by the pandemic. If an extension is put in place, CMS promises to provide proper public notice.
For additional information about CMS' plans for emerging from the COVID-19 pandemic, CMS recommends these resources:
For updates regarding Medicare Fee-For-Service medical review during the 2019-Novel Coronavirus Public Health Emergency, please download the Provider Burden Relief FAQ document. Do you have questions or concerns about the Recovery Audit Program? Please e-mail us at RAC@cms.hhs.gov. Please Do Not send Personal Health Information to this e-mail address.
©2020 by Rowan Consulting Associates, Inc., Colorado Springs, CO. This article originally appeared in Home Care Technology: The Rowan Report. Click here to subscribe. It may be freely reproduced provided this copyright statement remains intact. email@example.com