All Known Policies and Resource Updates Related to COVID-19

The Mississippi Rural Health Association has been working to develop policies and flexibility for providers in order to best protect themselves and meet the needs of their patients in a safe and effective manner.

We have provided an update, below, of all policy changes enacted by various state and national organizations related to COVID-19.  Please read carefully and call us at 601.898.3001 if you have any questions or need additional information.

Mississippi Division of Medicaid (DOM)

The Mississippi Division of Medicaid has added new procedure codes that can be used by providers and laboratories to bill for certain Coronavirus Disease 2019 (COVID-19) diagnostic to increase the testing and tracking of new cases.

The Healthcare Common Procedure Coding System (HCPCS) codes U0001 and U0002 were developed by the Centers for Medicare and Medicaid Services (CMS), and DOM is in the process of entering them into its claims processing system. They should be available for billing later this week, and they will apply to dates of service on or after Feb. 4, 2020. Providers will be notified once the codes are available in the system.

The HCPCS code U0001 is specifically used for CDC testing laboratories to test patients for SARS-CoV-2. HCPCS code U0002 allows laboratories to bill for non-CDC laboratory tests for SARS-CoV-2/2019-nCoV (COVID-19). The published fees for the two codes will be:

U0001 = $32.33

U0002 = $46.20

These fees do not include cutbacks, assessment fees, etc. Payment is not guaranteed.

For more information on the coverage or the evaluation and testing of COVID-19, find the following resources online:

Medicaid and CHIP Coverage and Payment Related to COVID 19

CDC Guidance on Evaluating and Testing Persons for COVID-19

Medicaid Updated Telehealth Regulations

In response to the coronavirus outbreak, the Mississippi Division of Medicaid (DOM) will expand its coverage of telehealth services throughout the state in alignment with Governor Tate Reeves’ recommendations on leveraging telemedicine to care for patients while limiting unnecessary travel, clinic visits and possible exposure.

Effective immediately through April 30, 2020, DOM’s Emergency Telehealth Policy will allow additional use of telehealth services to combat the spread of Coronavirus Disease 2019 (COVID-19). Details of enhanced services include the following:

  • A beneficiary may access telehealth services from his or her home.
  • A beneficiary may use his or her personal cellular device, computer, tablet, or other web camera-enabled device to seek and receive medical care with a qualified distant-site provider.
  • The requirement for a telepresenter to be present with the beneficiary is waived when the beneficiary receives telehealth services in the home.
  • Any provider that is eligible to bill DOM for services is now allowed to serve as a distant site provider, including Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs).
  • Any limitation on the use of audio-only telephonic consultations is waived.

These enhanced telehealth options will be available in fee-for-service Medicaid, Medicaid managed care, and the Children’s Health Insurance Program.

The agency also is seeking federal approval for an 1135 Medicaid waiver to give the program a wider range of flexibilities during the emergency. If approved, the 1135 waiver would give DOM the discretion, when necessary and proper, to relax prior authorization requirements, eliminate Preadmission Screening and Annual Resident Review (PASRR) reviews at nursing homes, suspend revalidations for current providers, and expedite new provider enrollment.

Other requested Section 1135 flexibilities include allowing care to be provided in alternative settings, revising rules for critical access hospitals, and relaxing telehealth security requirements so that providers can use readily available platforms like Facetime and Skype to facilitate telehealth visits with patients.

Additional information on policies, coding, and reimbursement related to the COVID-19 outbreak will continue to be added to a resource page on the agency’s website at

Providers are asked to direct their questions to 800-884-3222.

Note: To confirm, this now allows RHCs and FQHCs to be a distance site provider for Medicaid-reimbursed telehealth in Mississippi.  

Blue Cross Blue Shield of Mississippi   NEW

In response to the COVID-19 pandemic, Blue Cross & Blue Shield of Mississippi is ensuring expanded access to care, to include enhanced telemedicine coverage. This is important given the nature of the COVID-19 outbreak and the Centers for Disease Control and MS State Department of Health direction to self-isolate, not use the emergency room and call your primary care provider. Effective March 16, 2020, the BCBSMS COVID-19 Pandemic Telemedicine Policy allows Healthcare Providers to provide medically necessary services that can be appropriately delivered via audio and/or visual consultation. The BCBSMS COVID-19 Pandemic policy is effective March 16, 2020 through April 30, 2020, and will be reassessed as needed.

Specific guidelines are noted below:

  • Telemedicine, in this Policy, is appropriate for visits for either low complexity, routine or ongoing evaluation and management for established patients, as well as addressing new and established patient needs related to COVID-19 symptoms.
  • Member cost-sharing (co-pays, deductibles, etc) and benefit levels will apply according to the Blue Cross and Blue Shield Member’s Health and Wellness Benefit Plan. BCBSMS will waive the co-pay for all Network Provider covered telemedicine visits for fully-insured Members.
  • For routine evaluation and management of established patients, Healthcare Providers (MDs, DOs and professional Allied Providers, such as Nurse Practitioners) may bill for established patient evaluation and management codes up to a Level 3 (CPT codes 99211, 99212 and 99213) with a place of service 02 (Telehealth), regardless if provided telephonically or using visual equipment. Please note, however, providers should only bill for telephonic visits when the provider speaks directly to the patient. Providers should not bill BBSMS for services when only office staff and/or a nurse speaks with the patient, regardless if a provider was consulted.
  • To address new patient needs relative to COVID-19 symptoms, Healthcare Providers (MDs, DOs and professional Allied Providers, such as Nurse Practitioners) may bill for new patient evaluation and management codes up to a Level 2 (CPT codes 99201 and 99202) with a place of service 02 (Telehealth), regardless if provided telephonically or using visual equipment. Please note, however, providers should only bill for telephonic visits when the provider speaks directly to the patient. Providers should not bill BCBSMS for services when only office staff and/or a nurse speaks with the patient, regardless if a provider was consulted.
  • Behavioral Health Providers (Psychiatrists, Psychologists, Licensed Professional Counselors, and Licensed Certified Social Workers) may bill for established patient visits and evaluation and management codes as follows with a place of service 02 (Telehealth): -CPT codes 99211, 99212 and 99213 – CPT code 90832
  • All services must be medically necessary and documented as part of the Member’s permanent health record, to include the amount of time spent with the patient. Patient must give consent to be treated virtually and/or telephonically and appropriately documented in the medical record prior to initiation of telemedicine.
  • This policy only applies to medically necessary visits that are patient-initiated or are replacing a previously scheduled visit.

Mississippi Board of Medical Licensure (MSBML)

The Mississippi Board of Medical Licensure created recent policy changes that are in effect during the Governor’s State of Emergency:

1. Providers are highly encouraged to utilize telemedicine whenever possible for treating patients to avoid unnecessary clinic visits and possible exposure

2. The Mississippi Board of Medical Licensure shall allow non-Mississippi licensed physicians to provide telemedicine within Mississippi

3. Urine drug screens are not required for controlled substances, but use of the MPMP is still enforced.

View all changes

Mississippi Board of Nursing (MSBN)

The Mississippi State Board of Nursing created recent policy changes that are in effect during the Governor’s State of Emergency:

1. APRNs are highly encouraged to utilize telemedicine whenever possible for treating patients to avoid unnecessary clinic visits and possible exposure

2. Non-Mississippi licensed APRNs with an unrestricted out of state licensure are allowed to provide telemedicine within Mississippi

3. Point of service drug testing is not required for controlled substances, but use of the MPMP is still enforced.

View all changes

Mississippi State Department of Health (MSDH)

Prior approval from MSDH for submission of samples to the Mississippi Public Health Laboratory is no longer required.

TESTING SITES: The MS State Department of Health has posted a list of testing sites on its website.

Centers for Disease Control and Prevention (CDC)

CDC Infection Control Guidance: This updated guidance from the CDC provides updated PPE recommendations for the care of patients with known or suspected COVID-19. (Detailed information available on the CDC site.)

  • Facemasks are an acceptable alternative to N95 respirators when respirators are unavailable in healthcare settings. Respirators should be prioritized for procedures that are likely to generate respiratory aerosols.
  • When an adequate supply of respirators is available in a healthcare facility, facilities should return to use of respirators per their respiratory protection program.
  • Continue to use eye protection, gown, and gloves.
  • If there is a shortage of gowns, they should be prioritized for aerosol-generating procedures, high contact patient care activities, and activities where splashes and sprays may occur.
  • Patients with known or suspected COVID-19 should be cared for in a single-person room with the door closed. Airborne Infection Isolation Rooms (AIIRs) (See definition of AIIR in appendix) should be reserved for patients undergoing aerosol-generating procedures.


• LabCorp is accepting COVID-19 test orders and samples from physicians and other healthcare providers, clinics, and hospitals anywhere in the U.S. We are processing tests in the order received.

• COVID-19 tests can be ordered directly from LabCorp. We are not aware of any requirements that state or local health authorities must provide approval for LabCorp to perform testing. However, healthcare providers who are evaluating or treating patients under suspicion for COVID-19 may be required to coordinate with or provide information to their local or state health authorities. As noted above, testing should be conducted on appropriate patients in accordance with the latest

clinical guidance from the CDC and other expert organizations. Please check with those authorities for more information.

• LabCorp is reporting COVID-19 test information to public health authorities as may be required, but the ordering provider may also be required to report results and other information as well.

• CMS has established reimbursement in the amount of $51.31 for COVID-19 testing, and an HCPCS code for billing. LabCorp will use that rate for all customers, payers, and patients.

Please visit LabCorp’s COVID-19 website for the most current

Centers for Medicare and Medicaid Services (CMS)

Medicare will pay doctors and hospitals for a broad range of telehealth services on a temporary basis, effective March 6. The program will pay for office and hospital telehealth visits and include a wide range of providers including nurse practitioners, clinical psychologists and social workers. Telehealth visits will be reimbursed for the same amount as in-person visits.

CAH Swingbed Flexibility

CMS issued a Section 1135 waiver to allow CAHs and rural (non-CAH) swing-bed hospitals to move patients from their acute care beds to swing beds for extended care services without a 72-hour prior hospitalization. This clarification will help utilization review processes in rural hospitals to better maximize use of patient care beds.

Elimination of Geographic Restrictions

March 6, 2020, Medicare began temporarily paying clinicians to furnish beneficiary telehealth services residing across the entire country. In addition, the beneficiary generally could not get telehealth services in their home

Services and Providers

Under this Section 1135 waiver expansion, a range of providers, such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, can offer a specific set of telehealth services. The specific set of services beneficiaries can get include evaluation and management visits (common office visits), mental health counseling, and preventive health screenings. Beneficiaries can get telehealth services in any health care facility including a physician’s office, hospital, nursing home or rural health clinic, as well as from their homes.

Diagnostic Billing Code Tookit

CMS recently published a telehealth toolkit to assist providers in the new telehealth policies and diagnostic billing codes.

Co-Pay Requirements Waives

The Office of Inspector General stated that if a provider wishes to waive collection of the 20% coinsurance, they can and the OIG will not consider this a violation of the anti-kickback rules. This is voluntary.

To read the Fact Sheet on this announcement visit:

Department of Health and Human Services (HHS)

During the COVID-19 national emergency, which also constitutes a nationwide public health emergency, covered health care providers subject to the HIPAA Rules may seek to communicate with patients, and provide telehealth services, through remote communications technologies.  Some of these technologies, and the manner in which they are used by HIPAA covered health care providers, may not fully comply with the requirements of the HIPAA Rules.

OCR will exercise its enforcement discretion and will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency.  This notification is effective immediately.

This may include:

  • Facetime
  • Skype
  • Unencrypted Zoom / GoToMeeting, etc

This should not include:

  • Facebook live
  • YouTube
  • Other publicly facing streaming services

Read More


As part of the CARES Act, Congress has authorized Rural Health Clinics to be the “distant site” for telehealth visits. Until now, RHCs could only be the originating site for these visits. CMS is working on the guidance necessary to allow you to begin submitting claims for these visits but you can begin doing these visits as of March 27th Providers may need to hold these claims until billing guidance is issued.

The CARES Act establishes a $100 billion grant fund exclusively for health care providers who are enrolled in the Medicare and Medicaid program. The purpose of this fund is to provide grants to healthcare providers who have experienced a reduction in revenue due to the COVID19 pandemic.

The CARES Act creates the Paycheck Protection Loan Assistance program which expands and modifies an existing Small Business Administration (SBA) Loan program. What makes this “loan” program unique is that the government will be able to FORGIVE all or most of this loan if the business does not terminate employees during the pandemic. If the small business uses the loan to cover monthly expenses such as: payroll, continuation of health benefits for employees, rent, mortgage, utilities and interest on other loans you may have, then that portion of the loan will be forgiven.

Plans to Keep Mississippi Hospitals from Closing

Like many states in the nation, Mississippi is under a hospital crisis.  The reasons for the crisis are many, but the single greatest reason is that we are a state with few funds and many unhealthy citizens.  Combining this with low profit margins and increasing cost burdens for operations, it is no wonder why most Mississippi hospitals are designated as “at risk” for financial constraints or closures.

Mississippi has already lost six hospitals for full closure and six to bankruptcies.  Closures include Newton, Kilmichael, Belzoni, Natchez, Marks, and Senatobia.  Bankruptsies include Batesville (twice), Natchez, Clarksdale, Amory and Magee.

But, there are solutions that will help our facilities.  Most of these solutions were found through efforts of the Governor’s Rural Health Task Force, which convened in 2019 and produced a report with policy and legislative recommendations to assist all rural entities, including hospitals.  The recommendations were numerous, which well reflects the numerous issues that our facilities face.  These solutions primarily help with funding formulas, new funding pools for infrastructure, and increased access and efficiency.

Another positive solution comes from the Mississippi Hospital Association in the form of the Mississippi Cares plan.  This plan would utilize Medicaid funding and create a new provider-based insurance plan for low income citizens.  This would help to reduce uncompensated care and increase the insured rate of Mississippians.

Together, these solutions will help to solve our rural health crisis and help to support our rural hospitals.  Mississippi faces the same issues as other states, but being a poor state with low profit margins, we can’t afford to be wrong about the future of our healthcare.

RHCs to Receive Reimbursement Increase

The Mississippi Division of Medicaid recently announced that rural health clinics in Mississippi will receive a 1.9% increase in reimbursement for Medicaid encounters.  This rate increase will go into effect beginning January 1, 2020 for all RHCs in the state.  This reimbursement was initially passed by Congress and was funneled down through the Mississippi Division of Medicaid accordingly.

All clinics should have received a notice from the Division stating the increased rate and their new AIR including the 1.9% increase.

Click here to learn more.

For questions, contact Joe Jackson with the Division of Medicaid at 601.359.4040.

MRHA Partner Releases Book Focused on Hospital Survival

“Rural Hospital Renaissance” Gives Nation’s Struggling Rural
Hospitals Pathway to Growth and Revival”

New book and survival assessment tool provide at-risk hospitals with
a blueprint for engaging leadership, staff and patients to reverse the 
epidemic of closures and start growing.

A fifth of the nation’s rural hospitals are nearing collapse, according to North Carolina’s Sheps Center for Health Services Research, and 2019 is on pace to record the highest number of closings ever. With rural hospital closures at a crisis point, finding the pathway back to growth has never been more urgent.

“Rural Hospital Renaissance,” the new book by Brian Lee, one of North America’s leading experts in the field of Five Star patient experience, offers rural hospitals a proven formula for achieving a breakthrough in the patient experience to transform their future prospects from decline and survival to growth and revival.

“A cultural renaissance is needed in healthcare today,” says Lee, of the industry’s renewed focus on improving the patient experience. “The magic takes place when leaders truly engage the frontline with a ‘License to Please’ bundle of empowerment skills that transform their task-driven efforts to mindful presence and kindness. This book provides a step-by-step blueprint for transforming hospital culture and engaging caregivers to create a healing experience that patients will enthusiastically recommend.”

Lee says the patient experience is critical for rural hospitals, where patient volumes are declining due to the “drive-by factor” as tens of millions of dollars are lost to competing nearby urban tertiary hospitals. Because patients in these communities often rely on recommendations from their neighbors, friends and family when selecting a healthcare provider, “advertising will not bring back patients who don’t like you,” Lee emphasizes. “Word of mouth, will.”

“Rural Hospital Renaissance” explores evidence-based best practices that rural hospitals should take to engage patients and create a positive experience of healing kindness, including the four must-haves to become the hospital patients recommend: a culture of caring, frontline engagement, leadership and patient engagement.

“The patient experiences empathy and compassion through the actions of empowered frontline caregivers who become ‘patient relationship experts,’” Lee explains. “That’s why moving from decline and survival to growth and revival takes a strong commitment and some simple but profound changes in leadership and frontline behaviors. By following the practical, easy-to-do best practices outlined in this book, a renaissance is possible for every rural hospital. These are mostly simple things that leaders and caregivers can do while they’re doing what they already do, and they don’t cost a cent.”

Included in the book, Lee and his company Custom Learning Systems (CLS) introduced the Rural Hospital Renaissance “Survival Index” tool to help hospitals gauge their risk. While conventional research focuses on lagging indicators such as financial and volume factors tied to revenue, the Survival Index takes a proactive, comprehensive view by examining all the leading quality indicators that ultimately impact a hospital’s ability to survive in today’s economy.

Also launching as part of this effort is “,” and Facebook page “Saving Rural Hospitals” dedicated to addressing the epidemic of rural hospital closings. offers insights and resources, including the Survival Index Tool, for healthcare leaders and anyone who has an interest in being part of this movement.

Lee formally released “Rural Hospital Renaissance” in his keynote address to the Indiana Rural Health Association on National Rural Health Day, November 21, 2019.

About Brian Lee

Learn more about Lee here.

About Custom Learning Systems Ltd. (CLS)

Learn more.

Contact Bruce Lee at or by phone at 1-800-667-7325 ext. 213

Message from Charles James Regarding RHC Modernization Act Analysis

Below is a message from Charles James, president and CEO of the North American Healthcare Management Services, regarding the need for clinics to modernize and the need for the RHC Modernization Act.  We thought this was good to share!

Dear all –

I had a chat with John Gale after a recent exchange on the NRHA Grassroots listserve.  I had also recently heard John on an a radio Rural Hospital Closure Interview with a Kaiser Health News reporter, on which John did a great job framing our crisis.  (I had been meaning to call him!)

The listserve exchange demonstrated the persistent friction and misunderstanding b/w RHCs and FQHCs.  For me – all conversations lead to the the RHC Modernization Act. (Right – Bill 😉) John brought up the topic of the also persistent need for RHC data.  His team, Maine Rural Health Research Center/University of Southern Maine, recently released an analysis which demonstrates what many of us know and have discussed.  John and I also discussed RHCs lack of participation in Quality Payment Programs.  John was gracious enough to forward me their study, as well as recent presentations of his.  He also allowed me to share them.  I found them essential reading and thought you would too.

My own summary is that:

  1. Data supports our need to get in front of CMS on “RHC Modenization”, and the existential threat of of “site neutral payments” to PBRHCs.
  2. RHCs need to get IN on Quality.  Easy solutions exist:  PCMH = Advanced APM.  State Quality Program participation counts as well, in line with recent CMS-QPP guidance.  (eg MO has a fantastic PCMH program)
  3. RHCs could participate in Quality Payment Programs via HCPCS Code reported on their UB04 for various quality measures and UDS reporting.
  4. We must continue and strengthen our conversation with our FQHC cousins on how to collaborate, how we fit with one another, and how we differ.

That is likely more than $.50, but there it is.  I look forward to speaking with you all –

Best Regards –

Charles A. James, Jr.

President and CEO

North American Healthcare Management Services

9245 Watson Industrial Park • St. Louis, Missouri 63126

888.968.0076 Office

314.560.0098 Cell


Mississippi Governor’s Rural Health Task Force Report Released

It is my pleasure to report to you that the Mississippi Governor’s Rural Health Task Force report was delivered to Gov. Phil Bryant on Monday of this week.  This report is the culmination of multiple meetings across four months with a hand-picked committee of fifteen professionals, many of which are active MRHA members.  I had the pleasure of serving as the chair of this task force, representing and considering each of you as we had discussions and considerations of how to improve our state’s rural health system.

The task force focused on three key areas: sustaining and evaluating the current healthcare infrastructure, growing access, and transforming current healthcare practices into those of the future. These areas were intended to determine the root causes of Mississippi’s rural health issues and provide solutions specific to addressing those solutions.

The solutions in this report are those that the task force felt would best help to solve Mississippi’s rural health concerns.  The solutions include policy and legislative recommendations as well as opportunities for rural health strategy.

Now that the report is finished, the work can begin!  This report will serve as a roadmap for Mississippi for years to come, and we look forward to being a dedicated partner for substantial, system-wide improvements.

Download the Governor’s Rural Health Task Force report

Thank you for your continued membership, confidence and support.  We cannot do this without you!


Ryan Kelly
Executive Director
Mississippi Rural Health Association

NRHA Hosts Summer Leadership Symposium

Each year the National Rural Health Association hosts its summer leadership symposium.  This event brings together association leaders from across the country to learn from one another and share best practices on operating a rural health association and growing outreach and involvement in each respective state.  Ryan Kelly represented Mississippi at this meeting and was able to share many of the great updates from Mississippi.
“As the MRHA has grown in size and scope, the association has become a leader in the nation by helping other, smaller associations to learn how to develop membership and run events and programs.  And, in turn, we have learned a great deal from other associations,” responded Kelly.

To learn more about the National Rural Health Association and to join online, visit

MRHA Leaders Attend NARHC Conference in St. Louis

MRHA leaders Sharon Turcotte (MRHA president, Rush Health Systems), Susan Campbell (MRHA past-president, Rush Health Systems), Paula Turner (MRHA 2017 president, North Mississippi Health Systems), and Sherry Lindley (MRHA secretary, North Mississippi Health Systems) attended the National Association of Rural Health Clinics (NARHC) meeting this week in St. Louis.  At this meeting, Susan Campbell was inducted as a new member of the NARHC board of directors.  Congrats to Susan, and a big thank you for these leaders attending and learning more about rural health clinic operations.

Mississippi Cares Plan Offers Medicaid Reform Option

The Mississippi Hospital Association recently announced the development of a new health insurance model that would leverage Medicaid expansion dollars under the Affordable Care Act, and merge these into an insurance product through Mississippi True to form a new insurance program for Medicaid-expansion eligible citizens.  This plan, called Mississippi Cares, would extend Medicaid benefits to the prescribed 138% of the poverty level as according to ACA guidelines, but it would require enrollees to be a part of the private health insurance company with a $25 per month premium.  They would then receive all Medicaid benefits, and all providers would bill such claims to the provider-owned health insurance plan for reimbursement.
This new model is proposed at this time, but has drawn a great deal of support from healthcare professionals and industry leaders.  Now Vice President Mike Pence and CMS Secretary Seema Verma launched this plan when they served in leadership in Indiana.  Dubbed “PenceCare,” this plan links public funds with private industry to help solve one of Mississippi’s greatest healthcare issues, providing health insurance for the working poor.
More to come on the development of this new insurance model.