CMS releases provider-specific fact sheets on PHE waivers

Wednesday, February 22, 2023

CMS released guidance to help providers transition out of the COVID-19 public health emergency (PHE), which is expected to end on May 11.

The agency published 16 provider-specific fact sheets on the expiration of PHE waivers and flexibilities. These undated fact sheets have all been revised as of February 1 and are located on the Coronavirus Waivers & Flexibilities webpage.

The fact sheets detail the timeline of waiver expiration dates for different providers, as well as policies and programs that have already been terminated or made permanent. Certain waivers are slated to end at the PHE conclusion, while others have been extended.

The American Hospital Association (AHA) released a special bulletin that highlights the key provisions mentioned in these waivers. Several notable policies and programs will be affected when the PHE ends, including the following:

  • Skilled nursing facility (SNF) bed requirements and availability
  • Bed limits and the 96-hour rule for average length of stay for critical access hospitals
  • Requirements for discharge to SNF, rehabilitation center, long-term care hospital, and home health agency
  • Medicare’s 20% add-on payments for patients diagnosed with COVID-19

The CMS fact sheets include information on telehealth services. Certain telehealth policies and procedures have been extended through December 31, 2024, including the following:

  • Waiver of geographic and location requirements
  • Reimbursement for audio-only services
  • Reimbursement for telehealth services furnished by federally qualified health centers and rural health clinics
  • Reimbursement for telehealth services furnished by physical therapists, occupational therapists, speech pathologists, and audiologists
  • Use of telehealth to recertify eligibility for hospice
  • In-person visit requirement for initiation of tele-behavioral health services

The AHA also sent a letter to HHS with recommendations on stabilizing the healthcare delivery system, supporting healthcare workers, and removing unnecessary administrative and regulatory burdens throughout the PHE conclusion.

Revenue integrity professionals should review all PHE waiver guidance that is relevant to their organization. Identify the expiration dates of pertinent policies and procedures to ensure compliance throughout this transition. Monitor for additional guidance on PHE waivers and any changes to expiration dates for the individual policies.

Editor’s note: Find more NAHRI resources on COVID-19 here.

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