The Public Health Emergency (PHE) was officially extended on April 15,2021 prior to its set expiration date of 4/21/21. The renewal, in alignment with statute, covers a 90-day period and though there have been discussions around the hill about it potentially being extended through 2021 we just don’t know that yet. Here’s what we do know, it’s time to plan for when the PHE does expire. So here are three things to do now in order to prepare:
- Evaluate your procedures. Many of us implemented temporary services for the PHE in order to keep seeing patients but some of the flexibilities allowed during the PHE will not continue. Here are a couple of notable items expiring with the PHE:
- Telehealth services for ER Visits (99281-99285), Critical Care (99291-99292), and Therapy services.
- Audio only telemedicine services. 99441-99443 and G2252 are reimbursable through the PHE but have not been made permanent.
- Understand COVID-19 Billing. The confirmed test for COVID-19 should be documented as ICD-10-CM Code: U07.1. Keep in mind how to document additional conditions/symptoms varies by whether or not this has been confirmed.
- Example: Pneumonia due to the coronavirus should have U07.1 (COVID-19) coded as Primary with J12.89 (other viral pneumonia) coded as secondary.
- Example: Patients presenting with signs/symptoms where a definitive diagnosis has not been established should be documented as the diagnosis code for the sign and symptoms established, not as COVID-19.
- COVID-19 Vaccines Billing. Do not bill the patient. There are numerous communications out about this so please do your research and do not balance bill patients. See the guidance from the Centers for Disease Control (CDC) for more information (link: https://www.cdc.gov/vaccines/covid-19/vaccination-provider-support.html ). You can bill insurance. Just make sure to document the correct code by manufacturer and to abide by the dosing intervals as dictated. And please take note of this special alert from the CDC and FDA:
On April 13, 2021, CDC and FDA recommended a pauseexternal icon in the use of Janssen COVID-19 Vaccine (Johnson & Johnson) out of an abundance of caution while they review data involving a small number of U.S. reports of cerebral venous sinus thrombosis (CVST) with thrombocytopenia in individuals after receiving Janssen COVID-19 Vaccine. The Advisory Committee on Immunization Practices (ACIP) met on April 14. After hearing additional data on these reports, ACIP agreed that more information is needed before policy recommendations can be made regarding the continued use of the Janssen COVID-19 vaccine. CDC will collect more information and convene another ACIP meeting on April 23 to review any additional scientific evidence.
At this time, the recommended pause supersedes any other recommendations for use of Janssen COVID-19 Vaccine.
If we managed to get through 2020, we can get through the transitions of the PHE expiring. Though it isn’t happening yet, it will happen so make sure to prepare your staff accordingly. Consider keeping track of all vaccinated patients with a dedicated report as well as patients in your panel for whom vaccination confirmation has not been received. Reach out to patients to help them get scheduled at your facility and make sure to abide by the documentation requirements set out (link: https://www.cdc.gov/vaccines/covid-19/hcp/faq.html#vaccination-documentation ).
If your system will not allow you to quickly pull a report of this nature, give us a call. We can quickly and securely aggregate your data and perform a host of helpful services.