By Laura Freeman
With the end of the National COVID-19 Emergency in April and the COVID-19 Public Health Emergency on May 11, American healthcare is in a season of change.
Several of the policies, waivers and flexibilities put in place to cope with the overwhelming challenges of the pandemic are expiring. Many requirements that were moved to the back burner during the COVID crisis are being shifted back to the must-do list of things that will be enforced. Other programs and waivers are scheduled to continue through December 31, 2024.
To avoid a possibly expensive or inconvenient misstep as we work toward the new normal, now is a good time for providers to schedule their own internal checkup to see if there are any issues that need attention.
“Medicaid is one area where providers will want to make sure patients understand that they need to reapply to verify their eligibility for benefits,” Janet Day of Kassouf CPAs and Advisors said. “Letters have been going out for a while now, but we’ve heard that some Medicaid patients didn’t see them or didn’t know to expect them, while in other cases, the letter didn’t get to the right person.
“It’s going to be up to the patient or whoever is legally responsible for their care to open the letter, fill out the application and make sure it is mailed back in time.”
Credentialing for hospital privileges and other professional requirements is another area that may have slipped by the wayside during the pandemic when providers were struggling to find anyone who was qualified to care for patients. All credentialing and deadlines for important documents should be re-checked to make sure everything is current.
Telemedicine flexibility should continue through the end of 2024, but there are changes, mostly related to geography, HIPPA privacy rules and prescribing of controlled substances. HIPPA temporarily waived penalties for possible inadvertent violations, but this provision is ending.
“We are going to see some tightening of telemedicine requirements,” Day said. “Video telemedicine, behavioral and mental health visits have been extended through next year. Some of the public video apps we used during the pandemic may no longer qualify. To protect patient privacy, telemedicine video visits will need to be made using a secure video platform. This function may be available through some practice management or electronic medical records programs. Visits can originate from Federal Qualified Health Centers and Rural Health Clinics.
“Medicare will once again require providers to report their home address on the Medicare enrollment record. To continue making tele-visits from their home address, providers will need to complete a credentialing application and be approved by Medicare.”
Perhaps the most fundamental thing to know about telemedicine is that it can no longer be used to dispense controlled substances. Although this was a tremendous advantage for cancer patients and other immune compromised or housebound patients needing pain medication during the pandemic, physicians will now need to see patients in person before prescribing controlled drugs.
“Workforce flexibilities that allowed some nonphysician providers to work without direct physician supervision are returning to guidelines that were in place before the pandemic.” Day said. “Vaccinations will continue to be covered at no cost to patients by Medicare and most health plans. However, testing is another situation. Most free test kits have already gone out and future testing will likely need to be done at a health facility and most health plans will require patients to share the cost through co-pays or deductibles,” Day said.
Although the official emergency is expiring, the virus lives on. It has killed more than a million Americans and continues to kill more than 1,000 a week at current levels. In addition, a sizeable percentage of the people who survived the acute phase of infection are dealing with lingering health issues that may need treatment for an unknown amount of time.
Whether a patient needs care for a new infection or the lingering after effects, out of pocket expenses for some treatments may change, depending on the individual’s health coverage. Generally, COVID-related care is likely to be handled much the same as for any other illness.
Although any transition can have its bumpy spots, compared to the long days and nights of stress most health care providers went through trying to save lives while keeping themselves and their families safe, transitioning is just housekeeping.
And finally, the day we all wished for, when the pandemic would finally be over, may at last be near.
