Keeping up with CMS’ COVID-19 rules and guidance

Wednesday, July 1, 2020

The novel coronavirus (COVID-19) public health emergency (PHE) transformed hospital operations almost overnight. CMS responded quickly, issuing new codes for diagnosis and testing along with guidance for the new codes, emergency waivers, and a series of interim final rules with comment period.

CMS’ flurry of guidance and rules allowed hospitals to take critical action to respond to the rapidly evolving crisis. But for revenue integrity professionals tasked with keeping up with the latest COVID-19 billing and reimbursement news, it may sometimes have seemed overwhelming.

It’s impossible to predict how the PHE will unfold over the next several months. CMS may introduce new waivers, rules, and codes—but some waivers may expire. Although some industry stakeholders suggest that certain changes, such as expanded telehealth coverage, may be here to stay, there’s no guarantee that will be the case or what future coverage and reimbursement might look like.

NAHRI has striven to keep the revenue integrity community informed and connected throughout the PHE—and we will continue to provide the resources, news, and education our community needs.

Stay informed

Make sure you’re subscribed to NAHRI’s weekly e-newsletter Revenue Integrity Insider. Subscribing ensures you’ll get revenue integrity news delivered straight to your inbox every Wednesday afternoon. To help our members and subscribers make sense of the flood of COVID-19 billing and coding information, NAHRI’s editors comb through the rules, guidance, and waivers for those aspects that have the most impact on revenue integrity. These quick reads distill often-lengthy rules and communications into highlights that you can share with your colleagues.

If you aren’t already getting Revenue Integrity Insider, click here to sign up. You can browse the current issue and archives here.

To find CMS’ most recent rules, waivers, and other COVID-19–related information, visit the agency’s Current Emergencies page. The page includes links to guidance on telehealth, billing and coding, and coverage. It also includes links to CMS’ weekly COVID-19 stakeholder calls and transcripts. Resources are listed in order of most recent/recently updated, but always check the dates on FAQs, transmittals, and other documents to ensure they’re current. Pay particular attention to effective dates and implementation dates. If a modifier is made retroactively effective, for example, you may need to meet with leaders from coding, HIM, and compliance to explore your options.

For example, on claims for services for which the patient’s cost-sharing is waived, such as diagnostic testing and related evaluation and management (E/M) services, organizations should use modifier -CS (cost-sharing waived for Medicare Part B COVID-19 testing-related services), effective March 16. But because modifier -CS was made retroactively effective, that presents a dilemma. Should organizations run internal audits to identify claims the modifier might apply to? And if so, how should that be accomplished?

“One of the pain points that we’ve seen at some of our facilities is identifying the cases that we have to go back and add the modifier -CS on those E/M visits, as well as adding the condition code DR (disaster related) for the inpatient visits,” says Rachel Mitchell, CIC, COC, CPC, CRCR, associate vice president, HIM and CDI services, with Xtend Healthcare in Hendersonville, Tennessee.

In a perfect world, this could be done by simply looking for claims with ICD-10-CM code U07.1 (COVID-19). However, in the real world, practitioners don’t always clearly document the final diagnosis, and it might not be possible to identify every patient without manually reviewing all records with a date of service on or after March 16.

“Some hospitals that are smaller can do that, but at a larger health system it’s more difficult,” Mitchell says. “You can’t just audit everything from March 16 forward because there’s just too many and there’s not enough people to audit those records.”

The solution will depend on the organization’s resources and other factors and should involve senior leadership and compliance. Organizations must also keep in mind that if claims eligible for modifier -CS are missed, patients may be billed for the services when they shouldn’t be, cautions Melissa Caswell, CCS-P, director of coding, mid revenue cycle, with Xtend Healthcare.

“A lot of patients might just pay that, not even knowing or understanding that there’s a cost-sharing waiver,” Caswell says. “I think it’s a struggle that each individual organization will have to determine what’s the best course of action.”

And don’t forget to monitor state-specific Medicaid resources and commercial payer resources. Commercial payer guidance may be particularly tricky to manage, but it’s crucial that this information is available and current throughout the revenue cycle, from registration to billing and denials management.

Tracking and analyzing payers’ COVID-19 updates is a team effort, according to Elaine Lips, BS, RHIA, SHIMSS, mid revenue cycle strategy officer with Xtend Healthcare. A core group of directors, including revenue integrity, HIM, coding, and compliance, should meet regularly to share and discuss information and decide on coordinated action plans.

Ensure that a designated individual from your organization participates in CMS’ weekly COVID-19 Office Hours calls. During the April 23 episode of NAHRI’s biweekly podcast The Revenue Integrity Show, Angela Lynne Simmons, CPA, vice president of revenue and reimbursement at Vanderbilt University Medical Center, discussed how she shares information from the calls with her team and other leaders at her organization. The opportunity to participate in a dialog with CMS has been invaluable, she said, but she also makes sure to look for published references that support information given during the calls.

Understand the impact

Keeping pace with the changes can be challenging enough—but revenue integrity professionals also need to understand the impact on their organizations. Sharing expertise, analysis, best practices, and tips has never been more critical.

To help the revenue integrity community stay connected and informed, NAHRI launched a new, free biweekly podcast, The Revenue Integrity Show. The frequency and format of the half-hour episodes allows revenue integrity professionals to share best practices and have real-time conversations about hot topics. For COVID-19–specific information, listen to the following episodes:

  • April 23—COVID-19 Billing Implications: The Current Telehealth Landscape
  • May 7—COVID-19 for Revenue Integrity: The Perspective of a Physician and an Operations Expert
  • May 21—Advocacy Opportunities Now: Reviewing and Commenting on COVID-19 Rules and the IPPS Proposed Rule
  • June 4—Managing Clinical Research Finance During a Pandemic: A Focus on Revenue Cycle Impacts
  • June 18—Clean-up on Aisle [COVID] 19


You can listen to past episodes directly on the NAHRI site or via the following streaming platforms:


NAHRI’s members-only Quarterly Calls provide the opportunity to hear more in-depth expert analysis, ask questions, and qualify for one CHRI CEU. View the April 28 presentation to learn about adapting revenue integrity key performance indicators to COVID-19 and for tips on professional fee telehealth billing and coding. NAHRI offers one-time registration for our 2020 series of calls.

You can also take your COVID-19 revenue integrity questions to the NAHRI Forums. A dedicated COVID-19 topic allows members to quickly access the discussions they’re interested in. Once you’ve started or replied to a topic on the forum, you can choose to get notified of responses and other activity so you won’t miss anything.

Find tools, tips, and more information on HCPro’s COVID-19 Resource Center. The resource center offers tools and information to address everything from coding and reimbursement to infection control and staff safety.

Stay in touch

Social distancing has been crucial to slowing the spread of COVID-19 and saving lives. But it has also made staying connected and communicating more difficult. Keep in mind that during this time, more communication is better than less. Don’t hesitate to reach out to a colleague or a manager with a question, and make an effort to assure your colleagues that you’re available to answer their questions or provide support. Make the most of virtual networking and education opportunities and focus on positive things that you can accomplish.

That means we want to hear from you. NAHRI’s community is truly a collaborative effort. If there’s a resource or virtual networking or education opportunity you’d like to see NAHRI offer, let us know. We’re committed to serving our members and the larger revenue integrity community during these challenging times and in the future. Share your thoughts, ideas, and suggestions with us by emailing