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CMS released further information about the Medicare Accelerated and Advance Payment (AAP) program following the Continuing Resolution passage that revised the program’s repayment terms. Most notably, it appears CMS is automatically delaying recoupment for one year and will issue guidance on the recoupment process at a later date. The legislative text stated that CMS could delay payments “upon request” of the provider, and with this announcement, CMS will instead go further by automatically applying the delay to all recipients. From the announcement linked above:

Providers were required to make payments starting in August of this year, but with this action, repayment will be delayed until one year after payment was issued. After that first year, Medicare will automatically recoup 25 percent of Medicare payments otherwise owed to the provider or supplier for eleven months. At the end of the eleven-month period, recoupment will increase to 50 percent for another six months. If the provider or supplier is unable to repay the total amount of the AAP during this time-period (a total of 29 months), CMS will issue letters requiring repayment of any outstanding balance, subject to an interest rate of four percent.

Drew Voytal
Associate Director
MGMA Government Affairs
Washington, DC

HHS has extended the PHE for another 90 days as indicated in the announcement on this link and below. https://www.phe.gov/emergency/news/healthactions/phe/Pages/covid19-23June2020.aspx

Renewal of Determination That A Public Health Emergency Exists

As a result of the continued consequences of Coronavirus Disease 2019 (COVID-19) pandemic, on this date and after consultation with public health officials as necessary, I, Alex M. Azar II, Secretary of Health and Human Services, pursuant to the authority vested in me under section 319 of the Public Health Service Act, do hereby renew, effective July 25, 2020, my January 31, 2020, determination that I previously renewed on April 21, 2020, that a public health emergency exists and has existed since January 27, 2020, nationwide.

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Providers can now perform 89 telehealth services with a telephone call, CMS says

A phone call with a patient — plus complete documentation — will be all it takes to report 89 services on Medicare’s telehealth list. Practices will also be able to receive full reimbursement for 39 new services performed via telehealth according to the updated telehealth list posted today. The changes are retroactive to March 1. For the full article and list, visit the POET Ink File, CoVID-19.

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From MGMA April 30, 2020 – Changes to telehealth policy:

• Following MGMA advocacy, CMS is increasing payment for audio-only telephone E/M services (CPT codes 99441-99443) such that they are paid at the same rate as similar office and outpatient E/M visits, resulting in increased payments from $14-$41 to $46-$110. CMS believes that the resources required to furnish these services during the PHE are better captured by RVUs associated with level 2-4 established office/outpatient E/M visits. CMS is not increasing payment for CPT codes 98966-98968, which are intended for practitioners that cannot separately bill for E/M. This policy is retroactive to March 1, 2020.
• For telehealth services other than CPT codes 99441-99443 and 98966-98968 (now added to the list of covered telehealth services), Medicare continues to require modalities that have both audio and video capabilities.
• CMS is forgoing its typical rulemaking process to add new services to the list of Medicare services that may be furnished via telehealth. Instead, CMS will add new telehealth services on a sub-regulatory basis to speed up the process of adding codes to the list.