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Virtual Town Hall w/Asbel Montes

Your Questions. Answered Live.

June 17, 2020

Webinar Video Replay

Questions and Answers Transcript

If the Ambulance Service is Out of Network and no benefits paid, can we submit through the COVID Claim CARE Act portal?


This is for individuals who are uninsured (not uncompensated care). The intent of the uninsured dollars that were appropriated here were for individuals that did not have any insurance at all. However, if it is COVID related, there are some tweaks in there regarding deductibles. Some of you indicated that in some areas some insurance carriers are not paying anything for out of network. There has been sufficient pressure from some insurance commissioners in some states that has put pressure on those networks that it doesn’t matter if it is in or out of network, they should cover as if it was in network. You should not put that in and attest that it is an uninsured patient because if you do, technically you are falsifying the attestation. I suggest you work with your local insurance commissioner through these schematics because it has been successfully overturned in other states.




If we bill insurance and the charges are denied as non-covered, can we submit through the COVID Claim CARE Act portal?


I am questioning the non-covered for a COVID related patient based upon these nuances where many of your large major health payers are actually covering these treatment services. If it was an early date of service (before February 4) I would suggest get with the health plan who denied as non-covered to reprocess the claim. You shouldn’t technically have non-covered under the conditions of how this uninsured COVID related portal is going to work. This portal is only for patients who do not have insurance. You need to have a separate process for COVID and non-COVID related in case there is a processing error.




Could you clarify the need/use for special modifiers such as CS and CR?


This question is looking for guidance around Medicare/other payers wanting to use the CR for all COVID related claims. The CS is a modifier that will waive copays and deductibles. The CR modifier should be on all Medicare claims for COVID presumptive and COVID related claims as a tracking mechanism for Medicare. The CS modifier is a waiver. I heard from two different Medicare Administrative Contractors (MAC) that they are waiving it. I should know by Thursday if the CS modifier is appropriate to waive those copays. I do understand that there are two MAC’s that are suggesting ambulance services use the CS modifier to waive the copay and deductible; I have not been able to confirm this yet, but should have confirmation by Thursday of this week and can follow up with you on that.




For public government agencies who are registering for COVID-19 uninsured patient portal we are getting stuck at the very beginning where it asks for the Medicare ID and the tax classification. Typically we select “other” and then identify ourselves as government or municipality, etc. It does not give us this option. What recommendation do you have on this as we cannot continue?


I have not heard feedback yet regarding this. I did get receive feedback that they are following up on this issue to figure out a work around. I hope to have an answer by this evening on how to navigate through this issue.




Is the portal only for confirmed COVID or can you also submit suspected?


I have not asked this question yet because it can be perceived in the instructions that it includes both. It can also be perceived that it only includes those that are confirmed by using the U code after 4/1 or the B code prior to 4/1 depending on how you are reading the instructions. As a general rule for what I am doing, I am going to be submitting both at this time through the uninsured portal as I do not want to ask at this time since it can be interpreted both ways.




Will the treated in place (aka Treated not transported) be eligible for billing to HRSA for non-insured patients?


At this time, no, as they are only paying for services that are currently covered under the Medicare fee for service program. If it is a non covered service, it will not be under the uninsured.




Can non-hospital based private ambulance services bill through the HRSA website?


Absolutely, you can! This is open to everyone. Direction on governmentals should be available later this evening. If you haven’t registered, I suggest you do so today, as it is at least a two day process for you to be authenticated.




What is the timeframe from application to receipt of Tranche 2 provider relief funds?


Once your application is approved, they will distribute the funds every Friday as they receive/approve applications. It is anticipated and expected that many who applied should start to see the funding this Friday and every subsequent Friday until all approved applications are funded.




How specific do the patients’ complaints need to be to be considered a suspected COVID patient?


There has been CDC guidance that was given on how the questions to ask a patient to determine if they are a suspected COVID patient. I am assuming you are not using this guidance.




If you accept the first and second round of funding, how long do we have to not balance bill presumptive or positive COVID patients?


Most of the emergency rules/guidance is throughout the public health emergency. Once the PHE has been rescinded by the President of the United States, that is typically when everything ceases on the requirements from some of these waivers.




Insurance companies are still applying co-pays and deductibles when you use the Z correlated diagnosis Codes when you suspect somebody has COVID. Please advise.


I am assuming that an insurance company has indicated to you that they are waiving copays and deductibles for suspected COVID patients. The first thing you need to do is, did you follow the requirements as outlined by the health plan? If you did, then you need to engage the health plan. If you did not, then you need to correct your billing practices to do that. The second thing is, if you had followed those guidelines, you need to determine if ambulance service is included. I know just because there was guidance given by many of the health plans, I followed up with every single one of them to ensure that ambulance services were included in that guidance. I am suggesting to you to not take it they are intentionally excluding you; if you call them, they may have not realized they didn’t include you in it and need to modify.




The HHS portal for the uninsured (apparently linked with Optum Pay/United HealthCare) seems to be lagging (unless I did it wrong). I registered last week and I am getting various emails one time it states in process, then it states our ACH has been processed, then it later states it’s been changed back, etc. I called, they tell me it takes 7-14 days to finalize the process and it shows I am ok. Has this been the norm?


You are the first to report this to me. I am going to note this; if anyone else on the line has this concern as well, please email us so we can track it and follow up/report this issue.




When reporting Tranche 2, I understand there are many ways to look at the data but wanted to confirm they are only asking that you estimate your revenue loss for March and April only (not a full year of expected loss).


You are correct. They are only looking at March and April and it is an estimate. Remember that in an estimate you need to be able to justify. For some people who have relatively little growth year after year, it might be appropriate to compare where you were in March/April of last year to March/April of this year. Utilize a comparative pre-COVID quarter/month/year to what you would have anticipated had COVID had not happened to estimate that loss down to the March/April. Under an audit, you need to be able to prove your estimate.




We asked HRSA and were told that governmental entities should check the S core box and then check the state local government box below. Are you hearing this?


I have not heard this; if this is what they are telling you, this may be the solution but I haven’t been able to confirm yet. I hope to have an answer by this evening.




Would paying hazard pay bonuses to employees be a forgivable expense under the PPP?


Under the PPP, it is any cash, wages or money that is paid to an employee may be used for the purposes of the PPP funds. My suggestion is to make sure you document of any hazard pay/differential. Make sure you utilize the Department of Labor and Labor Standards Act weighted average overtime calculation should those individuals have hazard pay where they might have different rates of pay.




Does the HHS funding have an Expiration date to it as to when we are no longer required to accept the terms?


Typically, the terms and conditions would go through the PHE cycle.




Does the revenue loss estimate only apply to ambulance, or is this a general requirement for all providers including hospitals?


This number applies for any applicant for the 2nd tranche funding request for all healthcare providers and suppliers that do not do cost reporting. I am unsure what the “verification” process is for those providers that do cost reports.




The Terms and Conditions of the uninsured lead us to believe it's only for the Positive patients. Would this trump the instructions?


The T&C is unclear. I agree it “leads you to believe it is only for Positive patients”; however, it is not clear and there is an argument for ambulance services who do not diagnose patients that presumptive could be included. My suggestion is to submit uninsured claims for reimbursement that are presumptive and positive for reimbursement.




Please share the link to the sample form of the uninsured COVID-19 claims.


https://coviduninsuredclaim.linkhealth.com/claims-and-reimbursement.html





Virtual Town Hall w/Asbel Montes

Your Questions. Answered Live.

May 27, 2020

Webinar Video Replay

Questions and Answers Transcript

We have received 3 HHS Fundings and received an SBA Loan that can receive Loan Forgiveness. Are we able to get both or do we have to choose one or the other? Are they going to take back the HHS money if our SBA loan is forgiven?


The HHS funding and PPP funding are mutually exclusive; however, lost revenue and expense calculations are not. So when you are keeping record of all your expenses, you will want to back out those that were reimbursed under the PPP loan.




Is there attestation that requires signature just like in Tranche 1?


Yes. There is an attestation that has to be signed for tranche 2 funding. See link: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html




If I'm receiving partial PPE supplies from our Regional Advisory Council can I still use round 3 of funding for PPE?


Round 3 funding will look at increased expenses, including PPE. If you have received funding from other sources for PPE, you should not include this in your expense calculation. You; however, could include those expenses related to PPE that were not funded by other sources.




Asbel mentioned something regarding treatment site is that correct? Now if Medicare does pay for routine follow ups will that require a PCS form? PAN numbers were extended but nothing will be billed to Medicaid if the patient has Medicare? I think the wording factors in a lot because it is not specific , I am the type that likes to dissect what I am reading: Reference COVID-19: Expanded Use of Ambulance Origin/Destination Modifiers The reason why I am a little hesitant with it all is because our biller has billed every single routine and follow up appointment run to Medicare and it just does not convince me that it is being done correctly. EX: patient went to foot Dr. for an ingrown toe nail it was billed to Medicare and now she is telling me that a PCS form is required for every DR appointment.


Medicare did not waive any medical necessity requirements. They only waived the covered destinations, regardless if an emergency or non-emergency. A physicians office is now a covered destination under the PHE. PCS requirements were not waived either; however, if related to a COVID patient and due to CDC guidance CMS did issue the following regarding PCS signatures: See FAQ from CMS starting at page 22: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf




Why is the there a delay in payments from the Cares Act provider Relief distributions?


Due to the continued pressure the administration is receiving regarding the methodology on how they are distributing payments, they have increased pressure to ensure that the money is going to the individuals that need it. As the saying goes, with speed comes lack of precision. In order to keep the money flowing quickly it may not be as precise as many would like. They have instituted a few safeguards for a quality review of payments over a certain threshold. If you have not received funding in the 2nd tranche yet, it may be do to that or there could have been something regarding your inputs into the application that triggered a review as well. They will be rolling out funding in waves every Friday or you may receive a letter asking for additional information.




Can all of PPP funds be used for payroll? More than 75%?


Yes but not less than 75% for it to be forgiven.




How do we get transport to alternate destinations and telemedicine payments to be permanent for EMS?


This will take advocacy by our industry. The good thing is that CMS Administrator Seema Verma and HHS Secretary Alex Azar are on the record, on numerous occasions, that they expect to make many of the waivers permanent. However, we need to keep our grassroots advocacy up to make these waivers permanent.





Virtual Town Hall w/Asbel Montes

Your Questions. Answered Live.

May 5, 2020

Webinar Video Replay

Questions and Answers Transcript

If the Ambulance Service is Out of Network and no benefits paid, can we submit through the COVID Claim CARE Act portal?


This is for individuals who are uninsured (not uncompensated care). The intent of the uninsured dollars that were appropriated here were for individuals that did not have any insurance at all. However, if it is COVID related, there are some tweaks in there regarding deductibles. Some of you indicated that in some areas some insurance carriers are not paying anything for out of network. There has been sufficient pressure from some insurance commissioners in some states that has put pressure on those networks that it doesn’t matter if it is in or out of network, they should cover as if it was in network. You should not put that in and attest that it is an uninsured patient because if you do, technically you are falsifying the attestation. I suggest you work with your local insurance commissioner through these schematics because it has been successfully overturned in other states.




If we bill insurance and the charges are denied as non-covered, can we submit through the COVID Claim CARE Act portal?


I am questioning the non-covered for a COVID related patient based upon these nuances where many of your large major health payers are actually covering these treatment services. If it was an early date of service (before February 4) I would suggest get with the health plan who denied as non-covered to reprocess the claim. You shouldn’t technically have non-covered under the conditions of how this uninsured COVID related portal is going to work. This portal is only for patients who do not have insurance. You need to have a separate process for COVID and non-COVID related in case there is a processing error.




Could you clarify the need/use for special modifiers such as CS and CR?


This question is looking for guidance around Medicare/other payers wanting to use the CR for all COVID related claims. The CS is a modifier that will waive copays and deductibles. The CR modifier should be on all Medicare claims for COVID presumptive and COVID related claims as a tracking mechanism for Medicare. The CS modifier is a waiver. I heard from two different Medicare Administrative Contractors (MAC) that they are waiving it. I should know by Thursday if the CS modifier is appropriate to waive those copays. I do understand that there are two MAC’s that are suggesting ambulance services use the CS modifier to waive the copay and deductible; I have not been able to confirm this yet, but should have confirmation by Thursday of this week and can follow up with you on that.




For public government agencies who are registering for COVID-19 uninsured patient portal we are getting stuck at the very beginning where it asks for the Medicare ID and the tax classification. Typically we select “other” and then identify ourselves as government or municipality, etc. It does not give us this option. What recommendation do you have on this as we cannot continue?


I have not heard feedback yet regarding this. I did get receive feedback that they are following up on this issue to figure out a work around. I hope to have an answer by this evening on how to navigate through this issue.




Is the portal only for confirmed COVID or can you also submit suspected?


I have not asked this question yet because it can be perceived in the instructions that it includes both. It can also be perceived that it only includes those that are confirmed by using the U code after 4/1 or the B code prior to 4/1 depending on how you are reading the instructions. As a general rule for what I am doing, I am going to be submitting both at this time through the uninsured portal as I do not want to ask at this time since it can be interpreted both ways.




Will the treated in place (aka Treated not transported) be eligible for billing to HRSA for non-insured patients?


At this time, no, as they are only paying for services that are currently covered under the Medicare fee for service program. If it is a non covered service, it will not be under the uninsured.




Can non-hospital based private ambulance services bill through the HRSA website?


Absolutely, you can! This is open to everyone. Direction on governmentals should be available later this evening. If you haven’t registered, I suggest you do so today, as it is at least a two day process for you to be authenticated.




What is the timeframe from application to receipt of Tranche 2 provider relief funds?


Once your application is approved, they will distribute the funds every Friday as they receive/approve applications. It is anticipated and expected that many who applied should start to see the funding this Friday and every subsequent Friday until all approved applications are funded.




How specific do the patients’ complaints need to be to be considered a suspected COVID patient?


There has been CDC guidance that was given on how the questions to ask a patient to determine if they are a suspected COVID patient. I am assuming you are not using this guidance.




If you accept the first and second round of funding, how long do we have to not balance bill presumptive or positive COVID patients?


Most of the emergency rules/guidance is throughout the public health emergency. Once the PHE has been rescinded by the President of the United States, that is typically when everything ceases on the requirements from some of these waivers.




Insurance companies are still applying co-pays and deductibles when you use the Z correlated diagnosis Codes when you suspect somebody has COVID. Please advise.


I am assuming that an insurance company has indicated to you that they are waiving copays and deductibles for suspected COVID patients. The first thing you need to do is, did you follow the requirements as outlined by the health plan? If you did, then you need to engage the health plan. If you did not, then you need to correct your billing practices to do that. The second thing is, if you had followed those guidelines, you need to determine if ambulance service is included. I know just because there was guidance given by many of the health plans, I followed up with every single one of them to ensure that ambulance services were included in that guidance. I am suggesting to you to not take it they are intentionally excluding you; if you call them, they may have not realized they didn’t include you in it and need to modify.




The HHS portal for the uninsured (apparently linked with Optum Pay/United HealthCare) seems to be lagging (unless I did it wrong). I registered last week and I am getting various emails one time it states in process, then it states our ACH has been processed, then it later states it’s been changed back, etc. I called, they tell me it takes 7-14 days to finalize the process and it shows I am ok. Has this been the norm?


You are the first to report this to me. I am going to note this; if anyone else on the line has this concern as well, please email us so we can track it and follow up/report this issue.




When reporting Tranche 2, I understand there are many ways to look at the data but wanted to confirm they are only asking that you estimate your revenue loss for March and April only (not a full year of expected loss).


You are correct. They are only looking at March and April and it is an estimate. Remember that in an estimate you need to be able to justify. For some people who have relatively little growth year after year, it might be appropriate to compare where you were in March/April of last year to March/April of this year. Utilize a comparative pre-COVID quarter/month/year to what you would have anticipated had COVID had not happened to estimate that loss down to the March/April. Under an audit, you need to be able to prove your estimate.




We asked HRSA and were told that governmental entities should check the S core box and then check the state local government box below. Are you hearing this?


I have not heard this; if this is what they are telling you, this may be the solution but I haven’t been able to confirm yet. I hope to have an answer by this evening.




Would paying hazard pay bonuses to employees be a forgivable expense under the PPP?


Under the PPP, it is any cash, wages or money that is paid to an employee may be used for the purposes of the PPP funds. My suggestion is to make sure you document of any hazard pay/differential. Make sure you utilize the Department of Labor and Labor Standards Act weighted average overtime calculation should those individuals have hazard pay where they might have different rates of pay.




Does the HHS funding have an Expiration date to it as to when we are no longer required to accept the terms?


Typically, the terms and conditions would go through the PHE cycle.




Does the revenue loss estimate only apply to ambulance, or is this a general requirement for all providers including hospitals?


This number applies for any applicant for the 2nd tranche funding request for all healthcare providers and suppliers that do not do cost reporting. I am unsure what the “verification” process is for those providers that do cost reports.




The Terms and Conditions of the uninsured lead us to believe it's only for the Positive patients. Would this trump the instructions?


The T&C is unclear. I agree it “leads you to believe it is only for Positive patients”; however, it is not clear and there is an argument for ambulance services who do not diagnose patients that presumptive could be included. My suggestion is to submit uninsured claims for reimbursement that are presumptive and positive for reimbursement.




Please share the link to the sample form of the uninsured COVID-19 claims.


https://coviduninsuredclaim.linkhealth.com/claims-and-reimbursement.html





Virtual Town Hall w/Asbel Montes

Cutting Through the Noise

April 22, 2020

Webinar Video Replay

Questions and Answers Transcript

Wann ist eigentlich immer Kursbeginn?


Unsere Kurse beginnen im Normalfall IMMER sonntags um 10.00 Uhr. Einsteigen kann man aber trotzdem immer. Bei Anfängern bitten wir Sie uns kurz zu kontaktieren, da hier der Einstieg Mitte der Woche oft schwierig ist!




Gibt es eine Mittags- bzw. Ganztagsbetreuung?


Ja, natürlich! Die Gruppe- bzw. der/die Skilehrer gehen gehen gemeinsam essen.




Wie kann ich euch erreichen?


Entweder telefonsisch unter +436645158001 oder +436643187110 oder per eMail info@skischule-funny.at




Gibt es einen Familienrabatt?


Sicher. Ab zwei Kindern bekommen Sie 5 % Nachlass. Für individuelle Angebote bitte einfach melden.




Wie wird das Wetter morgen?


Im Normalfall schön und eine perfekte Piste. Für genaue Infos zum Wetter können Sie sich gerne für unseren genauen Wetterbericht per eMail anmelden.




Meine Frage steht hier nicht...


Sie können uns gerne unter 0043 6645158001 anrufen oder eine eMail an info@skischule-funny.at schreiben, freuen uns!





Navigating Reimbursement During the Next 90 Days of COVID-19 w/ Asbel Montes

April 8, 2020

Webinar Video Replay

Questions and Answers Transcript

Are there any concerns if a patient refused to sign prior to the FAQ and the crew noted “refused due to COVID” but we did not get a verbal? Are we still ok with billing these?


If you documented appropriately through the process and have a justification for it, I would bill it. It’s all about your documentation.




How do you know what the in network rate would be when you are an exclusive 911 provider and you have no in network rate at this point in time?


Unfortunately, it is left up to the insurance carrier. There is nothing in the clarification language that says they are going to use XYZ data base to determine the in network service; in your area if there is no 911, you do have an argument to say “I am the in network rate,” but it is ultimately left up to the insurance carrier. State law determines how the provider pays; most states have concept of reasonable and customary. If you don’t know what it is in your area, there is a fairly good website called fairhealth.org; put in your zip code and it will give you the in network rate in your area to give you a sense of what you will likely receive. Remember, states can only dictate rates that are major medical plans under state guidelines; all the ERISA plans are not governed under state guidelines.




Has Medicare issued a new fee schedule for the 2% sequestration relief effective May 1?


Your 2% sequestration is not off of the allowable fee schedule they post, it is off of the payment made. We do not anticipate there to be an issued new fee schedule.




What is the HHS attestation website to review and sign said attestation?


https://covid19.linkhealth.com/#/step/1




How do you know what the in-network rate would be when you are an exclusive 911 provider and you have no in-network rates?


Technically, your in-network rate should be what is set by the local jurisdiction. However, there are two databases that insurance carriers typically utilize to determine: www.fairhealth.org and www.healthcostinstitute.org.




How are you preparing for insurers processing claims as out of network when pursuant to the CARES Act T&Cs we are limited to in-network patient responsibility?


You have two options that I would implement within your organization: (1) Create a specific billing process for all COVID-19 claims that are coded with the U07.1 (Confirmed) or presumptive COVID (Z codes). For those claims that are OON and the insurance companies does not allow your full charge, set up an appeals process especially if you are in an exclusive market. You should challenge the difference between your billed charge and what they allow. Many insurance carriers are waiving copayments, even for OON claims but that is particular to each state. (2) I would make use of the Department of Insurance for enforcing state guidelines and recommendations to payers. This has proved successful in several states so far. You may have to work with your state associations for advocacy. I would definitely NOT just allow the insurance carriers to decide what they want to do regarding COVID related claims if the process is not justified.




What if we transport a patient who was not a PUI or postive at time of transport but after transport we find out patient was positive - do we need to be concerned about balance billing?


You should use a common sense approach. In your example, at the time of the transport and the indication of the medical documentation, you had no awareness of PUI or positive so your normal billing processes would apply. Most insurers have policies on how to submit claims (like Medicare does) for those patients that are know positive or PUI through ICD-10 coding guidelines or a specific modifier.




Is Medicare going to require the CS modifier to identify the cost sharing?


See attached length regarding the use of the CS modifier:
https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-07-mlnc-se




We have a positive COVID patient with no insurance, can we bill the patient?


Yes, you can bill the patient. The specific guidance indicates the following:
“The Secretary has concluded that the COVID-19 public health emergency has caused many healthcare providers to have capacity constraints. As a result, patients that would ordinarily be able to choose to receive all care from in-network healthcare providers may no longer be able to receive such care in-network. Accordingly, for all care for a presumptive or actual case of COVID-19, Recipient certifies that it will not seek to collect from the patient out-of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network Recipient.” COVID patients can only be considered in-network with a provider if they have insurance. It should be noted that CMS released guidance on 4/22/2020 that they will be setting up a portal at https://www.hrsa.gov/coviduninsuredclaim on 4/27/2020 that will allow for ground ambulance providers to participate in obtaining reimbursement for uninsured COVID patients.




Also the new "Hospital" 75 Million..... What do we expect to get from that and will it just show up in our Medicare payments like the last 6.3% did?


The appropriation for the $75B has not been passed the House as of the writing of this FAQ. However, we do anticipate it to pass and be signed into law. HHS has indicated in numerous press releases that the funding will continue to be more targeted so we expect that will happen with this $75B. ON 4/22, HHS issued new guidance on a second tranche of funding regarding the PHSSEF funding in the CARES Act ($100B). You can access it here: https://www.hhs.gov/provider-relief/index.html. If you are on Face Book, I have posted a short video explaining how to access this funding:
https://www.facebook.com/asbel.montes.3/videos/10222395212777968/?comment_id=10222396970421908¬if_id=1587657555793855¬if_t=video_comment&ref=notif





 
 
 
 
 

Last year, Solutions Group helped us avoid unmet deductibles on 65% of our accounts, yielding approximately $248,000 in increased revenue. We saw an average of $738 more per claim on the monitored accounts that later met their deductible.

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