COVID-19 Policies and Resources

This resource from the Centers for Disease Control and Prevention outline the guidelines needed and necessary to ensure a safe and effective ‘re-opening’ of the nation after the COVID-19 shutdown.

Safer at Home Proclamation

This updated proclamation from Governor Tate Reeves outlines the expanded opportunities for providers to provide non-essential services from April 27 – May 11, 2020.

Mississippi Division of Medicaid (DOM)

Effective 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 limitation on the use of audio-only telephonic consultations is waived.

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).

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

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

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 Pre-admission Screening and Annual Resident Review (PASRR) reviews at nursing homes
Suspend revalidations for current providers
Expedite new provider enrollment
Allowing care to be provided in alternative settings
Revising rules for critical access hospitals
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 https://medicaid.ms.gov/coronavirus-updates/.

Cost Report Deadline Extension

Due to the COVID-19 crisis, the Division of Medicaid has extended the due date for submitting rural health clinic cost reports with fiscal year end December 31, 2019. Cost reports should be submitted by July 31, 2020. If you have any questions, please contact Pamela R. Taylor, Office of Reimbursement, at pamela.taylor@medicaid.ms.gov or 601.359.3907.

Blue Cross and Blue Shield of Mississippi

Effective March 16 through April 30, 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.

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.

United Healthcare

UnitedHealthcare is waiving the Centers for Medicare and Medicaid’s (CMS) originating site restriction and audio-video requirement for Medicare Advantage, Medicaid, and Individual and Group Market health plan members from March 18, 2020 until June 18, 2020. Eligible care providers can bill for telehealth services performed using interactive audio-video or audio-only, except in the cases where we have explicitly denoted the need for interactive audio/video, such as with PT/OT/ST, while a patient is at home.

COVID-19 Testing-Related Telehealth Visits

From Feb. 4, 2020 and throughout this national emergency, UHC will waive member cost sharing for in-network and out-of-network COVID-19 testing-related telehealth visits, including both interactive audio-video and audio-only.

Cost Share Waived for In-Network Telehealth Services

UHC will also waive cost sharing for in-network telehealth services for medical, outpatient behavioral and PT/OT/ST services from March 31, 2020 until June 18, 2020 for Medicare Advantage, Medicaid, and Individual and fully insured Group Market health plan with opt-in available for self-funded employers.

For medical and outpatient behavioral telehealth visits, providers can utilize both interactive audio-video and audio-only. For PT/OT/ST provider visits, interactive audio/video technology must be used. For more details on PT/OT/ST telehealth, please click here.

Cost sharing will be waived for in-network telehealth visits. According to plan benefits, out-of-network providers also qualify for telehealth and member benefit and cost sharing will apply, if applicable.

View More Information

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:

Providers are highly encouraged to utilize telemedicine whenever possible for treating patients to avoid unnecessary clinic visits and possible exposure
The Mississippi Board of Medical Licensure shall allow non-Mississippi licensed physicians to provide telemedicine within Mississippi
Urine drug screens are not required for controlled substances, but use of the MPMP is still enforced.

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:

APRNs are highly encouraged to utilize telemedicine whenever possible for treating patients to avoid unnecessary clinic visits and possible exposure
Non-Mississippi licensed APRNs with an unrestricted out of state licensure are allowed to provide telemedicine within Mississippi
Point of service drug testing is not required for controlled substances, but use of the MPMP is still enforced.

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)

Transferring Patients to Relief Healthcare Facilities

The CDC released a guidance for state and local emergency medical planners and all healthcare facilities, especially facilities in rural areas. This guidance outlines considerations around the transfer of patients, staff, and supplies between healthcare facilities to optimize patient care, balance resources, and to minimize use of crisis care standards. Read More…

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.

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.

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 antikickback rules. This is voluntary.

To read the Fact Sheet on this announcement visit: https://www.cms.gov/newsroom/factsheets /

CARES Act

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.

Centers for Medicare and Medicaid Services (CMS)

Click here to view a special CMS link for all updated rural health policies (posted 8.20.2020)

Elimination of Geographic Restrictions

Services and Providers

Diagnostic Billing Code Tookit

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

RHC Code Updates

Distance site telehealth visits for RHCs must be billed with HCPCS code G2025. For distant site services rendered between January 27^th, 2020, and June 30^th, 2020, RHCs must bill G2025 with modifier CG. After July 1, RHCs will no longer need modifier CG. Furthermore, modifier 95 is completely optional for all G2025 claims.

Audio-only services such as the audio E/M services 99441, 99442, and 99443, may now be billed as G2025 services.

View More Details

RHC Telehealth Reimbursement Prior to June 30, 2020

All CMS G2025 claims prior to June 30, 2020 must be billed with modifier CG and will reimburse at the RHC’s all-inclusive rate. Beginning July 1, 2020 all these claims will be reprocessed to $92.03. After July 1^st, the CG modifier is no longer needed, and these claims will pay $92.03 from the onset. Guidance has been provided that CMS may recoup the difference between the all-inclusive rate paid prior to July 1, and the $92.03 fee schedule.

Co-Pay Requirements Waives

To read the recently released RHC billing practice form: visit www.cms.gov/files/document/se20016.pdf

To read the Fact Sheet on this announcement visit: https://www.cms.gov/newsroom/factsheets /

CMS Laboratory Reimbursement

Click here to download the latest CMS policies on lab reimbursement as well as a waiver of pre-authorization.

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

U.S. Department of Health and Human Services (HHS) announced new Guidance that specifies what additional data must be reported to HHS by laboratories along with Coronavirus Disease 2019 (COVID-19) test results. The Guidance standardizes reporting to ensure that public health officials have access to comprehensive and nearly real-time data to inform decision making in their response to COVID-19. As the country begins to reopen, access to clear and accurate data is essential to communities and leadership for making decisions critical to a phased reopening.

Full press release

The CARES Act/Paycheck Protection Program

Congress recently passed the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which allocates $350 billion to assist small businesses affected by the COVID-19 outbreak. The Paycheck Protection Program (PPP), one of the largest sections of the CARES Act, will provide government-backed loans from private banks that can, in some cases, be converted to grants. Under this program:

Eligible recipients may qualify for a loan up to $10 million determined by 8 weeks of prior average payroll plus an additional 25% of that amount.
Loan payments will be deferred for six months.
If you maintain your workforce, the SBA will forgive the portion of the loan proceeds that are used to cover the first 8 weeks of payroll and certain other expenses following loan origination.

Lenders may begin processing loan applications as soon as April 3, 2020. The Paycheck Protection Program will be available through June 30, 2020.

Click here to see if you qualify for a PPP loan.

Economic Injury Disaster Loans (EIDLs)

The CARES Act expands eligibility for the SBA’s Economic Injury Disaster Loans (EIDLs). In early March, the SBA’s disaster loan program extended to cover all small businesses affected by COVID-19, but the CARES Act opens this program up further and makes it easier to apply. Changes include the following:

EIDLs are now also available to Tribal businesses, cooperatives, and ESOPs with fewer than 500 employees. They are also available to all non-profit organizations, including 501(c)(6)s, and to individuals operating as sole proprietors or independent contractors.
EIDLs can be approved by the SBA based solely on an applicant’s credit score.
EIDLs that are smaller than $200,000 can be approved without a personal guarantee.
Borrowers can receive a $10,000 emergency grant cash advance that can be forgiven if spent on paid leave, maintaining payroll, increased costs due to supply chain disruption, mortgage or lease payments or repaying obligations that cannot be met due to revenue losses.

Click here to apply for an SBA Economic Injury Disaster Loan.

Emergency Contact Information

Office of the Governor of Mississippi Tate Reeves	(601) 359-3150 governor@govreeves.ms.gov
Mississippi State Department of Health	(877) 978-6453
Mississippi Emergency Management Agency	(601) 933-6362
Centers for Disease Control and Prevention	(800) 232-4636

MSDH Daily Brief Updates

Resources

Policy Updates

Centers for Medicare and Medicaid Services (CMS)

Emergency Contact Information

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