EPI Compliance and Healthcare Innovation Conference has been canceled. This should not be a surprise as many conferences have been canceled due to the COVID-19 crisis. The sad part was that we had an incredible number of speakers who were to offer fascinating information to all of us. Also, this was the first year we were to offer certification courses in regenerative medicine. We also had some courses geared towards diabetics, wound care, cannabidiol (CBD) uses for patients and much more.
Resources
Is your current patient volume less than 40% of what used to be? Has your gross income been reduced by 30% or more? Are you wondering how are you going to be able to pay your monthly bills? If the answer to any of these questions is yes, your Practice immune system is compromised and may soon need to be placed in the Intensive Care Unit (ICU).
People may find this callous based on the COVID 19 crisis but the reality of it all is that I see healthcare businesses as our patients and before this crisis many of these had their immune system compromised and COVID 19 will simply be the end of these Practices.
On an almost daily basis, I read something new regarding telemedicine updates and recommendations. The changes I read regarding telemedicine are unprecedented and the fact that President Trump declared a National Emergency makes it easier to forget about the rules and simply do what you can with this opportunity.
I have answered questions regarding HIPAA and telemedicine and even about using phones for voice interaction between patient and Providers. However, the fact that we have so much leeway doesn’t mean this is the wild west and that common sense can go out the door. Also, understand that there are many factors and legislative hurdles you may have to consider before engaging in telemedicine services. For your benefit, we are enclosing some of the HIPAA guidance released by the Office for Civil Rights as it regards COVID 19 as well as our recommendations as you move forward.
HIPAA. HIPAA has specific guidance as it relates to Emergencies, yet the COVID 19 resulted in specific guidance from the Office for Civil Rights (OCR). While the guidance is quite extensive some of the highlights include:
An accelerated/advance payment is a payment intended to provide necessary funds when there is a disruption in claims submission and/or claims processing. CMS is authorized to provide accelerated or advance payments during the period of the public health emergency to any Medicare provider/supplier who submits a request to the appropriate Medicare Administrative Contractor (MAC) and meets the required qualifications
Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. During public health emergencies, individuals can use interactive apps with audio and video capabilities to visit with their clinician for an even broader range of services. Providers also can evaluate beneficiaries who have audio phones only. CMS is allowing telehealth to fulfill many face-to-face visit requirements for clinicians to see their patients in inpatient rehabilitation facilities, hospice, and home health.
Just released March 31, 2020, CMS issued a Transmittal 2020-03-31-MLNC-SE – Providers can bill for telehealth visits at the same rate as in-person visits. Telehealth visits include emergency department visits, initial nursing facility, and discharge visits, home visits, and therapy services, which must be provided by a clinician that is allowed to provide telehealth. New as well as established patients now may stay at home and have a telehealth visit with their provider. During the COVID-19 pandemic, telehealth services should be billed using the place of service (POS) code that would have been reported had the service been furnished in person. For example, a physician practicing in an office setting who sees patients via telehealth, instead of in person, would report POS-11-0ffice. Additionally, the telehealth modifier (modifier 95) should be applied to claim lines that describe services furnished via telehealth.
The Federal Bureau of Investigation (FBI) has released an article on defending against video-teleconferencing (VTC) hijacking (referred to as “Zoom-bombing” when attacks are to the Zoom VTC platform). Many organizations and individuals are increasingly dependent on VTC platforms, such as Zoom and Microsoft Teams, to stay connected during the Coronavirus Disease 2019 (COVID-19) pandemic. The FBI has released this guidance in response to an increase in reports of VTC hijacking.
The Cybersecurity and Infrastructure Security Agency encourage users and administrators to review the FBI article as well as the following steps to improve VTC cybersecurity:
April 1st, 2020, Florida governor (Ron DeSantis) issued a statewide stay-at-home executive order (#20-91) requiring all non-essential businesses to close by 12:01am of this Friday 4/3/2020 (https://www.news4jax.com/news/local/2020/04/01/gov-desantis-addresses-state-as-covid-19-cases-grow/).
The order requires all persons in Florida to limit their movements and personal interactions outside of their home to only those necessary to obtain or provide essential services or conduct essential activities.
President Donald J. Trump signed into law the Families First Coronavirus Response Act (“FFCRA”) on March 18, 2020. It takes effect on April 1, 2020, so you must post by that date. The FFCRA requires covered employers to provide paid leave to employees for specified reasons related to COVID-19 through two major components: (1) the Emergency Family and Medical Leave Expansion Act (“EFMLEA”) and (2) the Emergency Paid Sick Leave Act (“EPSLA”).
On March 25, 2020, the Department of Labor published posters on its website for covered employers to use to notify employees of their rights under the FFCRA. Additionally, the Department of Labor published frequently asked questions discussing how and where employers must post this Notice.
Peripheral arterial disease (PAD) refers to atherosclerosis involving the aorta, the iliac artery, and the lower extremity arteries. The major risk factors for PAD are also common to other atherosclerotic diseases. They include smoking, diabetes mellitus (DM), renal failure, dyslipidemia, and aging.1,2 The natural course of chronic disease is difficult to predict. Symptoms do not always progress gradually from the severity to the next. Approximately half of patients suffering from critical ischemia have previously suffered symptoms of claudication and the first symptoms might be pain at rest and/or ulcers. DM is strongly associated with PAD. Among people with diabetes, PAD rate shows to be 11% compared with 4% among those without diabetes.3,4 Critical limb ischemia portends a severe diminution in quality of life and is associated to a high rate of amputation and a marked increase in short- term mortality.5-9
We understand that it’s a confusing time. Right now, you need all the resources and information you can get. We’re working to keep you updated so you can focus on keeping the country healthy and safe.
First and Foremost, Thank You
As the people on the front lines of COVID-19, we appreciate your efforts to fight this virus. To all health care professionals who are caring for sick patients and working around the clock to help find solutions – thank you for all you’re doing.
Expanding Access to Care and Resources
Here are key things to know, along with links, so you can get more information: