New Advisory from CDPH/LFS on Clinical Labs

Click Here to view the amended Advisory issued this week. 

Included in the notice is:
  • Emergency use authorization for COVID-19 tests
  • Amends Title 17 to add COVID 19 to reportable diseases to public health department within 1 hour
  • Governor's Executive Order of March 2nd waives current Business and Professions Code provisions allowing any personnel who meet the CLIA standard to perform high complexity testing to test for COVID during the existing emergency order
 
CMS Issues Waiver of Certain CLIA Reg Requirements
 
CMS has issued this memo to California and other states to suspend certain CLIA requirements due to the COVID outbreak. It includes the ability to review slides remotely, PT requirements among other significant exemptions. It is an instruction to California Laboratory Field Services as the CLIA inspection arm for California. CSP has reached out to LFS and CDPH to confirm that they will recognizing these inspection changes in the short term. Our question has been acknowledged but no formal reply as yet. We would expect them to follow this guidance. 

 
Medi-Cal Waiver Includes Temporary Increases in Lab Rates
 
DHCS submitted a waiver request to CMS on March 16th that included a number of changes to Medi-Cal Policy. It included a waiver on current rate methodology of no more than 80% of Medicare and an additional reduction of 10%. The waiver was granted last Friday and we are investigating the exact impact of these rate changes. The changes are effective March 1, but even if the rates changed you would not see them quickly since the claims processing system would have to be changed on the Fee for Service side. CSP will contact DHCS and provide additional information.

 
CMS Relief for Pathology Providers
 
CMS has announced two relief measures that can help pathology groups in this challenging time. Here are two articles with link about the changes:

Opportunity to Obtain Advanced Medicare Payments as Imaging Volumes May Drop in Certain Settings
 
Trump Administration Provides Financial Relief for Medicare Providers
Under the President's leadership, the Centers for Medicare & Medicaid Services (CMS) is announcing an expansion of its accelerated and advance payment program for Medicare participating health care providers and suppliers, to ensure they have the resources needed to combat the 2019 Novel Coronavirus (COVID-19). This program expansion, which includes changes from the recently enacted Coronavirus Aid, Relief, and Economic Security (CARES) Act, is one way that CMS is working to lessen the financial hardships of providers facing extraordinary challenges related to the COVID-19 pandemic and ensures the nation's providers can focus on patient care. There has been significant disruption to the health care industry, with providers being asked to delay non-essential surgeries and procedures, other health care staff unable to work due to childcare demands, and disruption to billing, among the challenges related to the pandemic.
 
"With our nation's health care providers on the front lines in the fight against COVID-19, dollars and cents shouldn't be adding to their worries," said CMS Administrator Seema Verma. "Unfortunately, the major disruptions to the health care system caused by COVID-19 are a significant financial burden on providers. Today's action will ensure that they have the resources they need to maintain their all-important focus on patient care during the pandemic."
 
Medicare provides coverage for 37.4 million beneficiaries in its Fee for Service (FFS) program, and made $414.7 billion in direct payments to providers during 2019. This effort is part of the Trump Administration's White House Coronavirus Task Force effort to combat the spread of COVID-19 through a whole-of-America approach, with a focus on strengthening and leveraging public-private relationships.
 
Accelerated and advance Medicare payments provide emergency funding and address cash flow issues based on historical payments when there is disruption in claims submission and/or claims processing. These expedited payments are typically offered in natural disasters to accelerate cash flow to the impacted health care providers and suppliers. In this situation, CMS is expanding the program for all Medicare providers throughout the country during the public health emergency related to COVID-19. The payments can be requested by hospitals, doctors, durable medical equipment suppliers, and other Medicare Part A and Part B providers and suppliers.
 
To qualify for accelerated or advance payments, the provider or supplier must:
  • Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider's/ supplier's request form,
  • Not be in bankruptcy,
  • Not be under active medical review or program integrity investigation, and
  • Not have any outstanding delinquent Medicare overpayments.
Medicare will start accepting and processing the Accelerated/Advance Payment Requests immediately. CMS anticipates that the payments will be issued within seven days of the provider's request.
 
An informational fact sheet on the accelerated/advance payment process and how to submit a request can be found here: www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf.
 
This action, and earlier CMS actions in response to COVID-19, are part of the ongoing White House Coronavirus Task Force efforts. To keep up with the important work the Task Force is doing in response to COVID-19, visit www.coronavirus.gov. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the Current Emergencies Website.
 

Waiver from Quality Reporting/MIPS Requirements

Quality Payment Program and Quality Reporting Program/Value Based Purchasing Program COVID-19 Relief
On March 22, 2020, CMS announced relief for clinicians, providers, hospitals, and facilities participating in quality reporting programs in response to the 2019 Novel Coronavirus (COVID-19). This memorandum and factsheet supplements and provides additional guidance to health care providers with regard to the announcement. CMS has extended the 2019 Merit-based Incentive Payment System (MIPS) data submission deadline from March 31 by 30 days to April 30, 2020. This and other efforts are to provide relief to clinicians responding to the COVID-19 pandemic. In addition, the MIPS automatic extreme and uncontrollable circumstances policy will apply to MIPS eligible clinicians who do not submit their MIPS data by the April 30, 2020 deadline.
 
You can find a copy of the memo here: Memo
 
You can find a copy of the fact sheet here: Fact Sheet