Complex Rehab Highlights on CMS Waivers and Rules

Published in Complex Rehab on April 02, 2020

CMS released new waivers and rules to increase the flexibility for healthcare providers during the COVID-19 pandemic. Here is a quick overview for CRT:

1. While it appears PT/OT may be eligible for telehealth there remains questions about the viability of billing and documentation therefore as of this notification telehealth for PTs and OTs is not recommended for the wheelchair evaluation (LCMP specialty evaluation).
2. CMS indicated that PA will be paused for certain DMEPOS items however as of this notification we don't know which items but are assuming power wheelchairs since they are one of only a few items that require PA and we do not know once implemented if this PAUSE means unavailable or optional. More to come.
3. This replacement disaster policy doesn't change anything as it is due to loss of item due to a disaster (such as hurricane, flood, etc.) which is not applicable to the Covid-19 emergency.
4. ATP involvement as of today remains the same as there is no guidance on that and trunk and limb measurements are required to determine the proper equipment therefore in person would still be practical.
5. Signature requirements HAVE BEEN Loosened (see below).
6. Advance payment is enacted (see below).

Signature Requirements: CMS is waiving signature and proof of delivery requirements for Part B drugs and Durable Medical Equipment when a signature cannot be obtained because of the inability to collect signatures. Suppliers should document in the medical record the appropriate date of delivery and that a signature was not able to be obtained because of COVID-19.

Accelerated/Advance Payments: In order to increase cash flow to providers impacted by COVID-19, CMS has expanded our current Accelerated and Advance Payment Program. An accelerated/advance payment is a payment intended to provide necessary funds when there is a disruption in claims submission and/or claims processing. CMS is authorized to provide accelerated or advance payments during the period of the public health emergency to any Medicare provider/supplier who submits a request to the appropriate Medicare Administrative Contractor (MAC) and meets the required qualifications. Each MAC will work to review requests and issue payments within seven calendar days of receiving the request. Traditionally, repayment of these advance/accelerated payments begins at 90 days, however for the purposes of the COVID-19 pandemic, CMS has extended the repayment of these accelerated/advance payments to begin 120 days after the date of issuance of the payment. Providers can get more information on this process here.