2021 Medicare Updates for Health Centers - January 25, 2021 - BKD, LLP
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2021 Medicare Updates for Health Centers January 25, 2021
To Receive CPE Credit • Individuals • Participate in entire webinar • Answer polls when they are provided • Groups • Group leader is the person who registered & logged on to the webinar • Answer polls when they are provided • Complete group attendance form • Group leader sign bottom of form • Submit group attendance form to training@bkd.com within 24 hours of webinar • If all eligibility requirements are met, each participant will be emailed their CPE certificate within 15 business days of webinar
Disclosure • The information contained within this session was used as a visual aid for informational purposes only. This content was not designed to be used without the verbal portion of the presentation • Accordingly, information included within these slides, in some cases, are only partial lists of requirements, recommendations, etc., & should not be considered comprehensive. In addition, reimbursement laws, regulations, & policies are subject to change • Providers should consult with their respective insurers, including Medicare contractors for specific information on proper coding & billing • These materials are being issued with the understanding they must not be considered legal, financial, coding, or billing advice
Copyright • CPT codes copyright American Medical Association. All rights reserved • CPT is a trademark of the AMA • Fee schedules, relative value units, conversion factors, &/or related components are not assigned by the AMA, are not part of CPT, & the AMA is not recommending their use • The AMA does not directly or indirectly practice medicine or dispense medical services. The AMA assumes no liability for data contained or not contained herein • Applicable FARS/DFARS restrictions apply to government use
Presenters
Jeffrey E. Allen, CPA Rebekah Wallace Pardeck, CMPE,
Partner CPC®, CPCO™
BKD, LLP President
Achieve Revenue ManagementAgenda • 2021 FQHC Reimbursement Rates • Medicare/Medicaid Cost Reporting During PHE • Benefit, Coverage, or Billing Changes • Q&A
2021 FQHC Reimbursement Rates
CY 2021
• CY 2021 Medicare Physician Fee Schedule Rule
Proposed released on August 4, 2020
Comment period ended October 5, 2020
Final released December 1, 2020
Revised December 28, 2020
https://www.govinfo.gov/content/pkg/FR-2020-12-28/pdf/2020-26815.pdf2021 FQHC PPS Reimbursement National rate $176.45 Geographic adjustment factor (GAF) based on locality is applied Payment based on the lesser of actual charge or PPS rate 2% payment adjustment (sequestration) suspended through March 31, 2021 https://www.cms.gov/files/document/2020-12-28-mlnc-se.pdf https://www.cms.gov/files/document/r10498cp.pdf
2021 Part B Calendar Year Increases
Premium: $148.50 monthly Deductible: $203.00 annually
https://www.cms.gov/files/document/mm12024.pdfMedicare/Medicaid Cost Reporting During PHE
Medicare Cost Report Changes
• Cost report due dates
• Medicare cost report is typically due 150 days after the provider’s reporting year
end, but the following deadlines were extended due to COVID
• As of now, no further cost report extensions have been announcedMedicare Cost Report Changes
• Telehealth
• CMS has added an additional line on the cost report for the cost of providing
telehealth services
• FQHC – Worksheet A Line 66
• MLN Matters SE20016 https://www.cms.gov/files/document/se20016.pdfMedicare Cost Report Changes
• Reporting telehealth costs
• Direct cost – allocate to appropriate telehealth cost report line
• Typically consists of salaries, benefits, & other costs related to telehealth providers & clinical
staff
• If costs are not captured on the general ledger, expense must be allocated
• Time studies
• Encounters (telehealth versus clinic)
• Indirect cost (overhead) – do not allocate
• Typically consists of facilities (depreciation, utilities, maintenance, housekeeping) & administrative
(front office, billing, IT, practice manager, CEO/CFO
• Work with cost report preparer to determine proper treatment for allocation of indirect costMedicare Cost Report Changes
• Telehealth visits & FTEs
• Since telehealth visits are paid outside of the FQHC PPS, visits & FTEs must be
excluded from the cost report
• Visits – Worksheet S-3 Part 1
• FTEs – Worksheet S-3 Part 3
• Assess if requesting a productivity standard exception is necessary after
removing telehealth visits & hoursMedicare Cost Report Changes
• Other COVID-related cost report nuggets
Specimen collection (including COVID-19) – included in
the FQHC PPS & not paid separately
FQHCs now are required to report aggregate revenue
received for Provider Relief Funds & PPP loan
forgiveness on Worksheet F-1, line 28.50Medicare Cost Report Changes • Other COVID-related cost report nuggets COVID vaccine – payment for COVID-19 vaccines & their administration in FQHCs will be implemented in the same way flu/pneumococcal vaccines are handled in FQHCs Influenza & pneumococcal vaccines & their administration are paid at 100 percent of reasonable cost through the cost report No visit is billed, & these costs should not be included on the claim The beneficiary coinsurance & deductible are waived
Benefit, Coverage, or Billing Changes
Principle Care Management (PCM)
• PCM services include comprehensive care management services for
• One complex chronic condition
• Lasting at least three months, which is the focus of the care plan
• Of sufficient severity to place patient at risk of hospitalization or have been
the cause of a recent hospitalization
• Requires development or revision of disease-specific care plan
• Requires frequent adjustments in the medication regimen
• Management of the condition is unusually complex due to comorbidities
2020-26815.pdf (govinfo.gov)Principle Care Management – FQHC
Effective January 1, 2021
Add HCPCS codes G2064 & G2065 to G0511 as a comprehensive care
management service
Payment rate for HCPCS G0511 is set at the average of the national nonfacility
PFS payment rate for: CPT codes 99490, 99487, 99484, & 99491), & (G2064 &
G2065)
Updated annually based on the PFS amounts for these codes
2020-26815.pdf (govinfo.gov)Evaluation & Management (E/M) Coding
• Effective January 1, 2021, criteria for determining level of E/M code changed
• Scope focused on E/M office or outpatient visits
• 99201-99205
• 99201 deleted
• 99211-99215
• Applies to all payors use CPT
• Eliminates history & physical as elements for code selection
• Code selection based on provider’s documentation of
• Medical decision making
• Total timeCOVID-19 Vaccine
“Because the initial supply of COVID-19 vaccines will be federally purchased…
primarily focuses on coverage of vaccine administration
Vaccine doses purchased with U.S. taxpayer dollars will be given to the
American people at no cost
Providers that participate in the CDC COVID-19 Vaccination Program
contractually agree to administer a COVID-19 vaccine regardless of an
individual’s ability to pay and regardless of their coverage status, and also may
not seek any reimbursement, including through balance billing, from a vaccine
recipient”
https://www.cms.gov/covidvax-providerCOVID-19 Vaccine
Part B coverage for COVID-19 vaccines & their administration without any cost-
sharing
Medicare beneficiaries, those in Original Medicare or enrolled in Medicare
Advantage, will be able to get the vaccine at no cost
Medicare pays 100% of cost
These rates will be geographically adjusted & recognize the costs involved in
administering the vaccine, including the additional resources involved with
required public health reporting, conducting important outreach & patient
education, & spending additional time with patients answering any questions
they may have about the vaccine
Coronavirus Aid, Relief, and Economic Security (CARES) ActCOVID-19 Vaccine – Medicare Advantage • Medicare beneficiaries enrolled in Medicare Advantage, will be able to get the vaccine at no cost • For calendar years 2020 & 2021 • Medicare will pay directly for the COVID-19 vaccine & its administration • Providers should submit COVID-19 claims to Original Medicare • MA plans will not be responsible for reimbursing providers to administer the vaccine during this time • MA beneficiaries also pay nothing for COVID-19 vaccines & their copayment/coinsurance & deductible are waived • FQHC impact
ABN Considerations • Advance Beneficiary Notice of Non-Coverage (ABN) • An advance written notice of noncoverage • Helps a beneficiary make informed decision about items & services Medicare usually covers but may not pay because they are medically unnecessary • FFS ABN • Note: The use of the renewed form with the expiration date of 06/30/2023 will be mandatory on 8/31/2020 1/1/2021
Questions?
Continuing Professional Education (CPE) Credit
BKD, LLP is registered with the National Association of State Boards of
Accountancy (NASBA) as a sponsor of continuing professional
education on the National Registry of CPE Sponsors. State boards of
accountancy have final authority on the acceptance of individual
courses for CPE credit. Complaints regarding registered sponsors may
be submitted to the National Registry of CPE Sponsors through its
website: www.nasbaregistry.orgCPE Credit • CPE credit may be awarded upon verification of participant attendance • For questions, concerns, or comments regarding CPE credit, please email the BKD Learning & Development Department at training@bkd.com
Connect with Us!
Jeffrey E. Allen, CPA Rebekah Wallace Pardeck, CMPE, CPC®, CPCO™
Partner President
BKD, LLP Achieve Revenue Management
jeallen@bkd.com rebekah@achieverev.comThank You! The information contained in these slides is presented by professionals for your information only & is not to be considered as legal advice. Applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor or legal counsel before acting on any matters covered
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